Studies have shown that exposure to sewage sludge and sewage sludge compost is
very dangerous. Two Countries acknowledge that sludge will cause Sewage Sludge
Disease to workers. The scientific name for Sewage Sludge Disease is extrinsic allergic
alveolitis. How much more deadly would it be for a person exposed 24 hours a day near
a sludge composting or disposal site?

Farm children often are exposed to sludge contaminants when they eat their own livestock
that have grazed on pastures with sludge, eaten vegetables from home gardens, and
ingested sludge directly off the ground, but the rule ignored these exposures (ORD
source commenting in Inside EPA, February 14, 1992, p. 10).

If EPA was not intent on killing people, why would it promote composting sewage sludge
and selling it as an unlabeled Class A fertilizer, when the same fertilizer would have to be
covered with soil in a landfill within eight hours of leaving the treatment process that made
it Class A.

§ 503.33(b)(5)
(9)(iii) When the sewage sludge that is injected below the surface of the land is Class A
with respect to pathogens, the sewage sludge shall be injected below the land surface
within eight hours after being discharged from the pathogen treatment process.

(11) Sewage sludge placed on an active sewage sludge unit shall be covered with soil or
other material at the end of each operating day.

It is unlikely that this same Class A unlabeled compost fertilizer could be placed within 75
feet of a 503 landfill boundary because Arsenic is limited to 30 ppm, chromium is limited to
200 ppm, and nickel is limited to 210 ppm.  And remember, that same Class A fertilizer
would have to be covered before days end. (Part 503.23  Table 2)

The following is an excerpt from the 1998 book:
Deadly Deceit
which shows just how deadly this Class A sludge fertilizer can be.

Residents in both urban and rural communities across the nation have suffered and are
suffering adverse health effects from exposure to pollutants from Class A sludge
composting and pelletizing sold as an unlabeled fertilizer.  Composting is the waste
disposal process which allows waste to decompose or rot. Composting is supposed to
destroy the disease causing organisms in a self-generated heat. Pelletizing is composted
sludge that is made into pellets for fertilizer.

In a letter to Kenneth Olden, the Director of the National Institute of Environmental Health
Sciences, Dr. Jordan A. Fink, Professor of Medicine, Chief, Allergy- Immunology Division
of the Medical College of Wisconsin and Dr. Melvin Kramer, an environmental and
infectious disease epidemiologist wrote of their concern that "municipal and commercial
composting is now being carried out on a nationwide basis...despite the fact that the
implications of composting for the health of surrounding community residents have never
been thoroughly studied."

They wrote:
 "It is clear that composting causes serious health-related problems for
 compost workers including an excess of nasal, ear, and skin
 infections, burning eyes and skin irritation, increased
 fungal colonies, and higher white blood cell counts and
 hemolytic complement."

 "It is reasonable to assume that surrounding communities
 (exposed to the facility 24 hours a day, rather than the
 8-hour work day) are also adversely affected, and anecdotal
 evidence indicates that may be the case." (p. 1)

Dr. Fink and Dr. Kramer's concern about the possibility of adverse health effects to
communities surrounding a compost site is well-founded. Both urban and rural
communities across the country are reporting illnesses associated by their nearness to a
composting facility. To mention just a few: Almaden, California in the West, Islip Township
and South Bronx in New York in the East, and Franklin, Kentucky in the South.  

Information on the adverse health effects suffered by residents in these selected
communities was obtained from personal interviews, correspondence and newspaper
articles.  These victims are not abstract faceless, bodyless figures generated by a
computer, they are living human beings
who have suffered from their exposure to sewage sludge. They are somebody's wife or
husband, mother or father, sister or brother, aunt or uncle, niece or nephew, grandmother
or grandfather or dear friend.  They are someone's children or grand-children. They live
in the city, the country or the suburbs.

Almaden, California

The residents in Almaden, a once healthy middle-class community in south San Jose, first
noticed the terrible odors, then residents began to develop an array of health problems:
skin rashes, respiratory and sinus problems, asthma, joint pains, dizziness, and severe
The culprit--a municipal open air composting plant that was releasing mold spores into the

Not only were residents of Almaden affected but schools were as well.  Children and
faculty of The Los Gatos Christian Church School, which was approximately 1000 feet
from the compost facility, experienced a remarkable increase in the number of upper
respiratory and sinus problems.

One of these Almaden residents is Jane Lilly-Hersley. Jane is an attractive middle-aged
woman of medium build with auburn hair and brown eyes who is very outgoing and
independent.  She is a Registered Nurse.  During the Vietnam War, she worked in a
Medivac Hospital in Japan.  She was a Surgical Intensive Care Nurse until twelve years
ago when she accepted a high level position at Roche Research in California conducting
clinical trials in areas of infectious disease, Immunology, AIDs and organ transplantation.

Jane is married to Dennis Hersley, a tall (6' 2") lean, middle-aged man with a short salt
and pepper beard.  He is a chemist and computer consultant.  They have three beautiful
daughters, Cary, who is twenty-two years old, Laura who is twenty years old and Claire
who is eighteen years old.  

The oldest, slender-built golden brown-haired Cary, at 5 feet 9 inches is the tallest of the
three daughters.  Cary is interested in becoming a researcher.  Middle daughter, Laura, is
a petite five foot 4 inch; she has medium brown to auburn hair. Laura wants to be a lawyer
to fight against injustice.The youngest, dark brown-haired and dark-brown-eyed Claire, is
also five foot four inches tall.  Claire wants to be a researcher or a veterinarian.  

Everyone in the family has been adversely affected by the pollutant contamination in the
air from the compost plant.  After appeals to the city provided no action, Jane and Dennis
helped form a grass roots organization called Citizens United for Responsible
Environmentalism (CURE).

Excerpts from a personal letter Jane wrote to her former doctor describes vividly what she
and her family and neighbors were experiencing because of their proximity to the
compost facility:

 Even as I now write this story down on paper, an
 aura of unreality surrounds me. Half of my mind feels
 this situation is science fiction, that this weird
 situation cannot really be happening. Yet I too am ill,
 and have tested IgG positive to fungal pathogens with
 blood levels that frighten me.

    The nature of the environment we were living in at
 that time is hard to describe. One could not walk
 outdoors and take a breath without gagging and retching.
 Reports of these sickening odors came from as far away
 as 5 miles.  My sinus problems worsened terribly. My
 children were ill. My husband who has an inherited eye
 problem, Cogen's dystrophy, experienced 11 corneal
 erosions within a 6 week period. On nights when the
 stench was particularly acute, our animals became ill.
 Our two cats developed diarrhea and vomiting, fur loss,
 and behavioral changes. They were reluctant to go
 outdoors.  The baleful howl of the neighborhood dogs was
 a nightly serenade.

           In the meantime we were hearing complaints from
 other residents affected by the odors. Complaints ranged
 from many minor physical irritations, headaches, sinus
 infections, skin rashes, sleeping difficulties, ear and
 eye irritations, to more troublesome ones, such as
 bronchitis, and yet more serious ones, intractable
 asthma and pneumonia.  For those residents who sought
 medical treatment for their complaints, some recovered
 very slowly, requiring extended treatment to achieve
 relief from their symptoms. In other instances
 individuals sought medical treatment but presented
 baffling cases to their doctors who were unable to
 effectively treat their conditions.

Many doctors refused to get involved. However,  they were able to enlist the help of Dr.
Vincent Marinkovich, who had been treating a family with three cases of colonization by
aspergillus, one a ten year old child who was seriously ill.

Dr. Marinkovich, who is in his 60s, is of medium build, 5' 10" tall, with salt and pepper hair.
Jane describes him as "a man ahead of his time". She says, "he is a very gentle,
compassionate man who has a unique scientific mind. He is a creative thinker who will
consider other ideas besides what is in the book."

Dr. Marinkovich is a medical doctor with Board certification in pediatrics and in allergy
immunology.  He is a clinical associate professor at Stanford University Medical
School. He is an expert in his field having spent almost twenty years treating lung disease
both at Stanford and in his private practice. He spent a year studying in England with
professor Jack Pepys at the Brompton Cardiothoracic Institute in London.  Professor
Pepys was world renowned for his work in the area of hypersensitivity lung diseases.  
Most of these lung diseases were known to be caused by inhalation of bacterial spores.

To gather information on the illnesses suffered by the residents, Dr. Marinkovich and
CURE conducted a survey of the affected residents and tested their blood.  Seventy eight
adults and 117 school-aged children were surveyed and the blood of 266 residents was
tested for IgG antibodies in the blood using the MAST test.  This test measures the
normal immune system response (IgG antibody levels) to significant exposure to various
substances, including the environmental
molds aspergillus, alternaria, cladosperium and penicillum.

The higher the antibody level, the more significant the exposure to the individual immune
system. The survey showed a considerable increase in illness above what was expected
under normal conditions and over what was the norm before the composting was started.  
When the blood levels of the residents living near the compost facility were compared with
those of residents living several miles away, the residents living near the compost had
high IgG and antibody levels to Aspergillus, that appears to thrive in compost.

According to Dr. Marinkovich:

     Aspergillus is a well-known human pathogen. It is the
 scourge of the modern hospital in that its control is
 difficult.  It kills patients with diminished immunity
 and can cause serious illnesses in exposed individuals
 who are otherwise normal.  Some species produce
 aflatoxin, the most potent cancer-producing chemical
 known, bar none.  Its optimal growth temperature is 37
 degrees centigrade, which is human body temperature. It
 easily colonizes damaged human tissues such as sinuses
 and lungs.  Once established, it is very difficult to
 eradicate. (p.  3 of statement for CURE)

Dr. Marinkovich stated unequivocally in his Statement on the Health Hazards from
Generated By Compost/Sludge Waste Treatment Using Biological Method that, "As one of
the physicians who      personally examined and tested many of the patients who reside in
the valley, I have no doubts about the serious  health hazard of chronic fungal spore
dissemination over
a residential area."

When the information from the survey and blood tests were compiled and presented to
the City and State by CURE, no action was taken to help them. According to Jane "Neither
the City nor the State health office has assumed responsibility for the risk residents are
being exposed to. Passing the buck from department to department is the course of
action they have elected to follow." She adds further:

I find it incredible that in the face of our complaints,
no health study or risk assessment is being undertaken
by the health agencies of our state.  Governmental
agencies are in fact continuing to open new operations
across the bay area without the proper and necessary

scientific study required to determine safety.  I fear
dire consequences may result before government
recognizes the folly of recklessly implementing
technologies that are inadequately researched...There is
a problem in Almaden.  We need someone to pay attention,
and we need help to find some answers.

When Jane Lily-Hersley conducted a nationwide inquiry to learn if other communities had
been adversely affected healthwise from composting or other sludge treatment
processes, she found that in the township of Islip, New York, the residents were
experiencing health effects similar to
Almaden residents.

A municipal composting facility was started at Islip in 1987.  Since its inception, residents
the facility were complaining of the terrible odors. Illnesses were increasing especially
asthma in children.

When Jane contacted The New York State Department of Health, who was soon to
release the results of their study of illnesses at Islip, she was provided, off the record, with
preliminary information confirming the presence of pathogenic fungi in tremendous
concentrations, when compared to background levels, at the compost site, and as far as
½ mile downwind from the facility. These organisms included a predominance of
aspergillus, as well as mucor, penicillium,
alternaria, cladosporium, and thermophilic actinocmycetes.
(Jane Lily-Hersley on p. 5 of her personal letter to her doctor)

Harry Dobin, who worked 1000 feet away from a compost site in Islip for 5 years, died from
aspergillosis. In excerpts from his poignant letter, Kenneth Dobin, tells of his son's terrible
suffering and death:

  From July 1991 until January 1992, the doctors
      treated him for asthma, arthritis, Weggener's disease,
 Lyme disease, kidney disorder, and bronchitis. Finally
 in January 1992, when he could no longer breath, they
 performed an open lung biopsy and discovered this fungus
 called aspergillosis had invaded his lungs. But, after
 being exposed for such a long period of time to this
 compost site, which is a natural breeding ground for
 this fungus, which took over my son's entire body. No
 antibiotic could stop this fungus.  Every time the
 doctors thought he was cured, it showed up somewhere
 else in his body.
         First his lungs, then he had an aneurism, then in his
 spine, then in his legs (which they wanted to amputate).
 After 15 months, this fungus destroyed him completely.
 It finally went to his heart valve and at that time the
 doctors decided not to remove his legs or replace the
 heart valve, but we should make him as comfortable as
 possibly and let Harry pass on and end his suffering.

      On September 23, 1992, five days after the fungus
 invaded his heart valve and legs, Harry died.

         From January 1992 until his death, Harry was
 hospitalized for the most horrible illness imaginable. I
 will never forget his suffering.

New York City

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.

The plant is owned by the New York Organic Fertilizer Company (NYOFCO), which is a
subsidiary of Whellabrator, which in turn, is a subsidiary of Solid Waste Management of
Illinois, the biggest waste conglomerate in the nation.

I am personally acquainted with one of the teachers at PS 48.  Unfortunately, which says
something for free speech in the United States today, I can not reveal her identity
because she fears reprisal. She has already been demoted once because of her activities
to stop the pollution that has made so many of them ill.  Although I can't mention her real

I can tell you that Ms. X is one of the most dedicated and caring teachers, who wants to
make a positive difference in the lives of her students, that I have ever met.  The first time
I met her I was touched by her heart-wrenching account of the situation at PS 48 where so
many children, day after day, were suffering from a range of symptoms--burning eyes,
coughing, nausea, stomach cramps, nosebleeds, sore throats, and asthma. She said she
had to do something.  She couldn't stand by and ignore the silent unspoken pleas in their
sad little eyes asking for someone to do something to make it better.

Ms. X has worked tirelessly in the children's cause. Working with Jane Lilly-Hersley of
Almaden, she organized a branch of CURE.  When she wrote as an individual to various
regulatory agencies (City and State) protesting the situation at PS 48, her letters were
ignored.  It wasn't until she sent letters with the CURE letterhead that her letters were
even answered. All of her activities and those of several other teachers, and some
parents who were fighting the air
pollution proved to be of no avail; no one in any position of authority in the City or State
would help them.  It wasn't until United States Representative Jose Serrano of New York
became involved in their struggle that anything was done to alleviate the distressing
situation at PS 48.  

When Representative Serrano held a hearing at the school and learned the extent of the
adverse health effects the students were experiencing there, he was appalled. In a
personal interview, Rep. Serrano told Jack Newfield of the New York Post that he was
taking immediate action to remedy the appalling situation.  According to Newfield, Serrano
was asking the federal EPA to test the air around PS 48.  He also wanted a court
injunction to stop the pollution.  

Several articles were written by the New York Post which aptly portrayed the situation at
PS 48 in Hunts Point.  In a follow up to his February 13th article, Jack Newfield on
16th wrote a hardhitting article entitled "Something Stinks in Hunts Pt." in which he told
about two scandals in the South Bronx. The first scandal was the accelerated asthma rate
(32%) among the students of PS 48 which was within a mile of more than 40 sludge,
sewage and garbage disposal facilities. The second scandal was the inactivity of the city
and state environmental and health agencies who appeared unwilling to test the air
quality around the school to discover what it contained that was causing the asthma
epidemic.  Newfield ends his article with the admonition to the federal EPA, the mayor and
the governor to step in, take decisive action and end the buck-passing that had been
going on, before a child dies from asthma.

Someone finally paid attention. In a conversation with Ms. X, she told me that the health of
the children and faculty had improved since NYOFCO was forced to install an air control
device totaling 1.6 million dollars.  The plant also replaced the foul-smelling air with the
smell of cinnamon, lilac or almond. The sludge hauling trucks are also no longer permitted
to drive on the streets near the school.

Unfortunately, now the residents of Hunts Point have to fight a new threat.  A Marine
Transfer Station is to be built there  to receive the sludge coming in by barges.

Franklin, Kentucky

In Franklin, Kentucky, 131 neighbors, who lived around the Triple M. Landfarm, which in
July 1997 began composting385 tons of sludge from Nashville, Tennessee and six other
cities, have become ill. Symptoms of the residents include vomiting, diarrhea, nausea,
lack of appetite, fatigue, headaches, respiratory problems, dizzy spells, sinus problems,
and muscle aches. Several residents have infected fly bites from the flies that have been
attracted to the compost pile. The leader of the group of neighbors, who have been trying
to stop the composting, is Bonnie Swayze. Bonnie and her family live on the farm that has
been in their family since 1891.  She is an attractive  middle-aged medium build woman
with blond hair and blue eyes. She is married to 5' 11", 200 lb. Bruce Swayze who has
brown eyes and grey hair.

They have two sons, Bo and Billy. Both boys are tall and slim. Bo, who is thirteen, and
Billy, who is ten, both have brown hair and hazel eyes. These usually healthy, energetic
boys have been suffering from fatigue and repeated bouts of diarrhea. Billy also
developed a staph infection due to fly bites.

Bonnie and Bruce are both suffering from fatigue.  Bruce also has joint and muscle pains.  
Like her sons, Bonnie has bouts of diarrhea.  Her other symptoms include sore throat,
blisters on the tongue and fly bites.

Like those in other parts of the country, who have tried to stop the composting, pelletizing
and land application of sewage sludge that have made people ill, particularly children,
Bonnie and her neighbors met with the same indifferent treatment by regulatory agencies.
 The State epidemiologist, who was sent to investigate the problem and who said it would
take months to do the study, has never returned. The State Health Director, who attended
one of their meetings, and listened to their complaints about the adverse health problems
they were experiencing, told them
that he was directed by the Governor to close down the compost site but he couldn't do it
without documented proof of their health problems.  Two doctors at the meeting said they
could verify the health problems Bonnie and her family  and neighbors were experiencing.
He left and the compost facility is still in operation.

Although sludge brought in from out of state was stopped, in state sludge is still being
transported to the compost facility and the neighbors are still getting sick. To add insult to
injury, Bonnie and her neighbors, who have suffered ill effects from the composting, are
being sued by
the sludge hauler for interfering with his business.

What has happened in Almaden, Islip, the South Bronx, Franklin, and other communities
over the United States was no surprise to Dr. Melvin Kramer who unequivocally pointed
out in an executive summary of October 1, 1992, the harm to communities from
composting and pelletization of sludge.  He says:

      Therefore, this methodology of de-watering and
 composting sludge and pelletization will pose a
 significant health hazard to the population in general,
 but especially to the elderly, children, and the infirm,
 both in terms of nuisances as exemplified by excessive
 putrid odors and minor allergic reactions in the general
 healthy population (such as runny noses, itchy and runny
 eyes, sore throats and coughs) to life threatening
 diseases (such as invasive Aspergillosis, especially in
 immunocompromised persons who have such disease entities
 as cancer or leukemia, who have had bone marrow or organ
 transplants, or who are positive for the human
 immunodeficiency virus or who have clinical AIDS.
 Furthermore, of the 10%-15% of the general population
 who are asthmatic, Aspergillus will exacerbate and cause
 asthmatic attacks and, in a small minority, will cause a
 condition which is most severe called Allergic
 Bronchopulmonary Aspergillosis, {ABPA}.
What happened to the residents of Almaden, Islip, South Bronx, and Franklin could
happen to you or your family. We are all potential victims of Class A sewage sludge sold
as unlabeled fertilizer.  It matters not where we live.  Whether we reside in the country, a
large city, the suburbs or a small town, we are not protected from exposure to this most
deadly killer.
Part 503.23
Table 2
level allowed
0-25 meters
of surface