Deadly Deceit  
                                          CHAPTER 3

Marketing a Dirty Product

Together EPA and the Water Environment Federation

(WEF), with its 40,000 membership involved with waste water

treatment, have put together, under the expert guidance of

the blue chip public relations firm, Powell Tate, a plan

called Biosolids 2000. The purpose of this plan is to gain

worldwide acceptance of toxic sludge as a fertilizer by

local governments, farmers, and the public (us) by the year

2000.  If this plan to market a dirty product succeeds there

will be many more victims. While any one could be victim, it

is more likely that it will be our children, or grand-

children or our elderly parents who will be the next victims.

In their investigation of this public relations campaign

of the EPA/WEF, John Stauber and Sheldon Rampton, authors of

Toxic Sludge Is Good For You, say it "revealed a murky tangle

of corporate and government bureaucracies, conflicts of

interest, and a coverup of massive hazards to the environment

and human health." According to these authors, "The trail

began with the Water Environment Federation--formerly known

as the "Federation of Sewage Works Associations"--and led

finally to Hugh Kaufman, the legendary whistleblower at the

hazardous site control division of the Environmental

Protection Agency." They say Kaufman, who exposed the

corruption in the EPA during the Reagan administration, which

led to the fall of Anne Burford, the EPA Administrator, is

"attempting to raise a similar alarm about the so-called

beneficial use" of sewage sludge, a boondoggle he refers to

as 'sludge-gate'...the mother lode of toxic waste." (p.  101)

When Stauber and Rampton were researching the use of

public relations in the marketing of sewage sludge for their

book, Toxic Sludge Is Good for You, they requested that the

WEF/EPA provide copies of its strategy documents, memos,

opinion surveys, and other material from Powell Tate, the PR

firm handling the promotion.  When they refused to

voluntarily produce the documents, Stauber and Rampton were

forced to file a Freedom of Information Act request with the

federal government before they were given some of the

documents by EPA.  Legally Stauber and Rampton were entitled

to these all of the documents, since both the WEF and EPA

receive taxpayer funding.

In looking through the documents Stauber and Rampton

finally received, it became obvious why the EPA/WEF were

reluctant for Stauber and Rampton to obtain them.  They

revealed a shocking story of how the EPA/WEF with the help of

Powell Tate, were mounting a major campaign to foist toxic

sewage sludge, with a name change to biosolids, upon an

unsuspecting public (you and I). This campaign by the public

relations hucksters makes it very difficult for us to avoid

the dangers from the pollutants in sludge which includes

deadly disease-causing organisms (i.e., Salmonella, E-coli,

Listeria, etc.), organic chemicals (i.e., dioxins and PCBs)

heavy metals (i.e., lead, cadmium, arsenic), and in some

cases even radioactive materials like plutonium).

Taxpayers' money is funding this EPA/WEF scam, Biosolids

2000, where the public (you and I) is being deceived through

written material and presentations by selected spokespersons

that sewage sludge called biosolids is both safe and

beneficial for land application. The name and definition of

the very term biosolids is a coverup although Pete Machno who

came up with the idea for the name change told Stauber and

Rampton "It was not intended to cover something up or hide

something from the public." What else is it but a coverup?

Although biosolids is simply another name for sewage

sludge, it is being touted as a new product--defined as a

nutrient-rich organic byproduct of the nation's wastewater

treatment process. According to Powell Tate, "A powerful

message can be communicated that biosolids represent an

advance in technology and are a totally new, environmentally

friendly product." They say "For the campaign to succeed,

there needs to be a clear delineation between the new,

improved product and the old." Evidently when Powell Tate

wrote their communications plan, EPA, as a whole, had not

adopted the term biosolids to replace sewage sludge.

Why else would Powell Tate say this is one of the

obstacles in the promotion of biosolids. "Since the term

"sludge: carries many negatives, EPA's use of the term

"sewage sludge" instead of "biosolids" may neutralize the

agency's efforts to gain widespread acceptance of the term

biosolids," they say.  The National Research Council (NRC)

did not use the term biosolids as a substitute for sludge in

their study Use of Reclaimed Water and Sludge in Food Crop

Production which was commissioned by the EPA in 1993. In the

Preface of the study, they stated, "The committee focused

primarily on the issues surrounding the use of treated

municipal wastewater effluents and treated sludge in food

crop production..." Not all the members of the WEF were in

favor of the name change either.  J. Patrick Nicholson, CEO

of N-Viro International wrote in a November 7, 1995 letter to

John Stauber, "As one who has long believed that changing the

name from sludge to bio-solids was stupid, there is much in

Joel's article and your book with which we agree."

Before writing their Communication Plan for the WEF/EPA

promotion of sewage sludge (biosolids), Powell Tate conducted

over 100 interviews with national and regional opinion

leaders on issues relating to biosolids and sludge. Their

research showed that they had a real problem on their hands

in trying to sell this product to the public. As they wrote

in their report entitled Research Findings, July, 1993

"Indeed sludge has such negative connotations for the great

majority of respondents that as long as biosolids are viewed

as the same or even similar product, building support for

land application will be difficult." (p. 2)

Powell Tate recommended two main strategies to overcome

public resistance to the use of sludge on land.

The first strategy was to target "gatekeepers"

They define "gatekeepers" as individuals and organizations

who are asked by the public for their opinion on an issue

because of the expertise, authority or position." They say,

"Not only does the public look to them for their opinion on

an issue, but they are used as sources of information by

other gatekeepers--such as the media--when they, in turn,

sort out and form their opinions." Their list of gatekeeper

audiences includes (1) Academics/agricultural scientists,

(2) Water qualilty professionals, (3) Public health

officials, (4) Agricultural groups/farming representatives,

(5) Environmentalists, (6) Regulatory officials, and (7)

Media. Powell Tate selected these gatekeepers for "their

ability to help us address one or more of the obstacles

outlined in the section on strategic imperatives.  For

example, public health officials lend credibility to messages

concerning health, agricultural experts can address questions

about scientific research, and environmentalists bring

support for environmental messages."  (p. 21) They stressed

that "Educating gatekeepers on biosolids recycling,

therefore, is a critical first step."

The gatekeepers attention is to be diverted from the

product, sewage sludge, to the process recycling which is the

second strategy of Powell Tate. From their research they soon

realized that if EPA/WEF were going to be successful in

selling sludge (biosolids) for land application, they had to

shift the focus from the product to the process. They said "A

key contributor to resistance about biosolids land

application is the nature of the product itself.

Consequently, a second strategy, to be reflected in the

messages, is to play down the product itself (biosolids) and

focus attention, on the process (biosolids recycling)."


The recycling strategy was a clever ploy because as

Powell Tate said "recycling has many positive connotations

for the audiences we want to reach as well as the general

public, therefore we want to pair it with biosolids [sewage

sludge] as much as possible." (p. 15) In many local

communities there are designated places where residents bring

paper, glass, tin, and aluminum for recycling. Science

teachers often involve their classes in recycling projects.

The recyling theme is to be emphasized throughout the PR

campaign in either the written material for distribution or

in the presentations of chosen spokespersons.

Although Powell Tate recommended a full blown media

relations campaign with media tours around the United States,

press conferences, press releases, an op-ed placement program

and other activities, there was no funding for such a media

blitz.  In place of the costly media campaign, EPA/WEF

adopted Powell Tate's suggestion that they assemble an

information kit complete with a 8 to 10 minute video,

brochure and information sheets to give to a "highly targeted

media list of food, agriculture, environmental, consumer, and

health reporters as well as other gatekeepers (individuals

and organizations who because of their expertise, authority

or position become an information resource for the public on

an issue)". (p.  40) They recommended that carefully edited

clips of the video be developed into B-roll and distributed

to the broadcast media.  B-roll is footage used by television

as "filler" for news stories and is usually labeled as "file

film" when shown. For radio, they say, we can produce and

feed radio stations 60-90 second soundbites (called

"actualities") of spokespersons audio used in the video.

These actualities are then edited by the stations into radio

news stories.  They further suggested that the B-roll and

actualities be produced and distributed in place of the

proposed audio and video public service announcements...

"Since B-roll and actualities are used in news broadcasts,

they have much greater credibility than PSAs sponsored by an

interest group," they say.  (p. 26)

The audiovisual materials for the kits were to be

tailored to each region of the country with regional

spokespersons (farmers, scientists, public health officials)

providing testimonials to sewage sludge safety and beneficial

reuse to provide what Powell Tate refer to as "a down home

community feel so that people will be comfortable with

biosolids recycling."

Although the total kit was only sent to selected

persons, the brochure and information sheets were available

to the public.  Two of the information sheets were developed

to extoll the beneficial recycling of sewage sludge.  WEF

information sheets followed the Powell Tate recommendation.

The title of the first information sheet proclaims in capital

letters "Biosolids Recycling and Beneficial Use."  In this

sheet, biosolids is defined (a nutrient-rich organic material

resulting from the treatment of wastewater) and its

beneficial use is stressed. The title of the second sheet is

also in capital letters "Biosolids Recycling: Replenishing

the Earth." The message contained in this sheet is that

biosolids [sewage sludge] benefits the environment mainly "by

recycling a valuable resource rich in nitrogen, phosphorus

and other nutrients and promoting sustainable agriculture and

replenishing that which is taken out of the earth".

Although there is nutrient value in sludge, there are

other aspects of sludge not mentioned in the promotional

literature that negates its value when compared with

commercial fertilizers. In the first place, treated sludges

range from about 1 to 6 percent nitrogen on a dry weight

basis (Metcalf and Eddy, 1991) compared with 11 to 82 percent

in commercial fertilizers (Lorenz and Maynard, 1988) and

between 0.8 and 6.1 percent phosphorus (Metcalf and Eddy,

1991; Smith, 1973) compared with between 8 and 24 percent in

commercial fertilizers (Lorenz and Maynard, 1988).

While the nutrient properties in commercial fertilizers

can be formulated to suit the crop requirements, plant

nutrients in sludge can not be so controlled. This creates a

problem because when sludge is applied to satisfy the

requirement for one nutrient, levels of other nutrients may

either be excessive or deficient. According to the National

Research Council report, Use of Reclaimed Water and Sludge in

Food Crop Production, published in 1996, when sludge with the

nitrogen requirement is applied at a rate of 10 metric tons

per ha, available phosphorus may be excessive in many areas,

which could increase the risk of surface water contamination.

Another problem noted by the NRC is that the organic

forms of both nitrogen and phosphorus must be mineralized by

microorganisms before they are plant-available. This may take

more than a year. Unlike the organic forms, the inorganic

forms are available to the crops when they are first land

applied.  If organic nitrogen and phosphorus mineralization

are not accounted for, then overfertilization can occur that

can lead to leaching.  One of the dangers of

overfertilization of nitrogen, according to Asano and

Pettygrove (1987) as referenced in the NRC report, is that it

can cause excessive growth, reduce crop yield, and encourage

weed growth (p. 64) In this same report, the findings of

Bouwer and Idelovitch, 1987 were cited showing that excess

nitrogen has harmed the yield and crop quality of tomatoes,

potatoes, citrus and grapes.  (p. 64)

What the reports do not say is that crops grown on soil

with excess nitrogen are very dangerous to both humans and

animals.  Nitrate poisoning from hay grown on municipal owned

farms have killed animals from  North Carolina on the east

coast to California on the west coast.  According to Tim

Moran's article in the Modesto (CA.) Bee, dated July 7, 1996,

the City of Atwater, California was cited by the State

Regional Water Quality Control Board after 13 cows on two

different farms died from nitrate poisoning after eating hay

grown on the City's sludge disposal farm.  The City's farm,

operated by Metcalf Eddy Services, had received 238 pounds of

nitrogen in excess of the crop requirements.  Oats, alfalfa

and sudan grass are grown on the farm.

Lois Carson and Manuel and Ilda discovered that no one

would accept responsibility for the poisoned hay. While

Metcalf Eddy Services operates the treatment plant and farm

under contract, the City of Atwater is responsible for

compliance with the regulations during the operation of the

treatment plant and sludge farm.  The City is also

responsible for selling the contaminated hay to the two

farmers who lost their cattle.  Yet, the City claims it was

not negligent and denied both farmer's claims.

Ultimately we as consumers and land owners bear the

responsibility and the liability for the government's

actions. We have to remember that oats are not just for

cattle feed, they are also grown for human consumption.

Recently, Salmonella was discovered in toasted oat breakfast

cereal in the midwest.  If heat resistant bacteria is not

enough to be concerned about, how much excess nitrates in

your breakfast cereal does it take to affect the health of

your child?

When sludge is applied to land not only will there be an

increase of nutrients but also an increase in the level of

toxic heavy metals, toxic organic chemicals and pathogens

that can contaminate water and food crops.  Nine toxic heavy

metals are the only pollutants acknowledged under the Part

503 sludge rule.

In spite of the media hype to the contrary, recycling

human waste and industrial waste isn't like recyling aluminum

cans and newspapers. By passing biosolids off as a benign

user-friendly product, without revealing that it is full of

the same harmful deadly pollutants as sewage sludge, is

deception of the highest order both to the gatekeepers and we

the public.  EPA even uses deception in describing the affect

of a pollutant on humans. In the eyes of EPA, the public has

become organisms and as we saw in Chapter 1, individuals are

no longer considered to be a part of the general public.

In the Part 503 sludge rule EPA defines a pollutant as:

An organic substance, an inorganic substance, a

combination of organic and inorganic substances, or a

pathogenic organism that, after discharge and upon

exposure, ingestion, inhalation, or assimilation into an

organism either directly from the environment or

indirectly by ingestion through the food-chain, could,

on the basis of information available to the

Administrator of EPA, cause death, disease, behavioral

abnormalities, cancer, genetic mutations, physiological

malfunctions (including malfunction in reproduction) or

physical deformations in either organisms or offspring

of the organisms. [i.e., parents or children]

Although EPA acknowledges organic substances are

pollutants which can cause cancer, genetic problems, birth

defects and even death through the food-chain, they were

deleted by the EPA from consideration in the Part 503 sludge

policy rule.

EPA also deleted the word toxic from the regulation.

Yet, according to EPA, toxicity is the fourth common

characteristic of a hazardous waste.  The effects of toxicity

poisoning are exactly the same as those described for a

pollutant, they include death, cancer, genetic defects,

mental defects, physical defects as well as birth defects.

The individual or combined effect of toxic contamination by

disease organisms and chemicals may be quick acting or slow

acting, causing either acute or chronic health problems.

The organic chemicals that are present in sludge or

sludge-amended soils can accumulate in animals and humans

causing serious adverse health effects (i.e. toxicity).

Among these are the hydrocarbons, (e.g.,benezene and

toulene), and the halogenated hydrocarbons, especially the

chlorohydrocarbons (PCBs and dioxins).

Benzene, a clear, flammable, poisonous, aromatic liquid,

which is used as a solvent and in making a vast number of

derivatives used in plastics, insecticides, detergents,

paints, dyes, etc., may cause cancer and mutations. It causes

anemia and leukemia.  Toulene is a color-less, noncorrosive,

volatile liquid which is used as a gasoline additive, a

solvent for model glues, paints, inks, resins, and adhesives.

It is also used in the manufacture of detergents, dyes,

lacquers, linoleum, perfumes, pharmaceuticals, saccharine and

TNT. It can aggravate the respiratory tract, depress the

central nervous system and damage the liver and kidneys.

There is inconclusive evidence that it causes cancer.  Model

glue is composed mostly of toulene. If the glue is

intentionally sniffed, malfunctions of the nerves that

control movement and irregular heart rate can result; in some

cases, it may even lead to death.

When scientists added atoms of halogens--chlorine,

bromine and iodine--to hydrocarbons they created new

chemicals--the dangerous halogenated hydrocarbons. When

chlorine is combined with hydrocarbons, the most toxic of all

halogenated hydrocarbons are created--the chlorohydrocarbons

like PCBs, and dioxins. Chlorinated hydrocarbons are used in

pesticides such as the infamous DDT, dieldrin, chlordane and

endrin. Trichloroethylene and perchloroethylene are used as

degreasing agents and industrial solvents. Vinyl chloride and

polyvinyl chloride plastic are also made from chlorinated

hydrocarbons as is pentachlorophenol, a wood preservative

used to resist termites. When chlorine is combined with

benzene and oxygen, the most deadly of all chemicals is

formed--dioxin. The most dangerous of all the dioxins is

2,3,78-tetrachlorodibenzo-p-dioxin (TCDD)

Dioxin, which occurs in the environment in quantities too

small to be detected by either its appearance or odor, is

thought to be one of the most toxic of all the chemicals ever

made by humans.  Although there are a number of different

types of dioxin, the most dangerous is TCDD.  Dioxin is an

unavoidable by-product in the manufacture of certain

herbicides such as 2,4,5-T (Agent Orange). It is

inadvertently formed when paper is bleached with chlorine.

It is also formed when organic wastes that contain chlorine

are burned. Animal studies reveal that exposure to dioxin can

cause various types of cancers, liver and kidney ailments,

birth defects, and fetal death in domestic and wild animals.

Although the effects of dioxin is less certain for

humans, exposure to low levels over long periods of time may

cause cancer.  Exposure to as little as one-billionth of an

ounce of dioxin can cause chloracne.  Dioxins can persist for

years in soil. They accumulate in tissues.  Trace levels have

been found in the blood, fatty tissues, and breast milk of

humans and animals.  Because of the presence of dioxin in

breast milk, there is concern for the infants whose diet

consists mainly of this source of food.  Bottle-fed babies

are also at risk because dioxins are also found in cow's

milk. Recent studies suggest that Dioxin disrupts hormones,

impairs reproduction and weakens the immune system.

Polychlorinated biphenyls (PCBs) which are mixtures of

some seventy chlorinated hydrocarbons are also highly toxic.

They were created when chlorine was combined with

hydrocarbons known as phenols.  PCBs in the form of toxic,

colorless, odorless liquids, were used as insulating fluids

in electrical transformers and in the production of ink,

adhesives, copying paper, and lubricating oil. According to

Hare, Holdren, Schneider and Shirley, authors of Toxics A to

Z: A Guide to Everyday Pollution Hazards, PCBs in laboratory

studies produce "a variety of unwanted effects in diverse

test animals." (p. 383) The guide states:

PCBs can cross the placenta and are toxic to the embryo,

causing numerous adverse reproductive effects,

particularly increased stillbirths, spontaneous

abortions, and fetal absorptions. They also affect

survival in weanlings in rodents, monkeys, and mink. In

addition, following exposure to PCBs, the immune system

of rodents is suppressed; chickens exhibit changes in

the liver and edema in the young; and skin lesions are

produced in several species of animals besides humans,

including primates, horses and cattle.

In Toxic Threat: How Hazardous Substances Poison Our

Lives, Stephen Zipko, reports on animal experiments that

showed when PCBs were given to experimental animals, rats and

monkeys, there was cancer, miscarriages and infant mortality.

In the rat experiment, when rats were fed 100 ppm of PCBs in

their diet for twenty-one months, about 14 percent developed

some type of cancer; most had liver cancer. Only one of the

control rats who were not fed the PCBs developed cancer.  In

the monkey experiment, when two groups of female monkeys were

fed PCBs, one 5 ppm, and the other 2.5 ppm for six months and

then mated with males, who were not fed the PCBs, only one of

the eight females given the highest dose gave birth.  Of the

remaining seven fed 5 ppm, two never became pregnant and five

had miscarriages. Of the eight female monkeys fed 2.5 ppm,

five gave birth but to very tiny infants and three had

miscarriages. Three babies, out of the six babies who nursed

for four months, died. Others showed chloracne, abnormally

high activity, and problems in learning simple tasks. In

three months the nursing babies had reached the same

contamination levels as their mothers.

Although we do not know for sure the long-term effects

of PCBs on humans, on the basis of animal tests, they are

classified as a probable human carcinogen. They can be

absorbed by the digestive tract, skin and lungs.  In humans

they seem to produce an array of health effects--birth

defects, endocrine-disruption, chloracne, headaches, nausea,

loss of hair, fatigue, numbness, and liver problems.  PCBs

are persistent, they do not biodegrade, and they are fat

soluble so they biomagnify through food webs. Nearly everyone

has been exposed to PCBs through consumption of water or

contaminated foods, especially fish and probably waterfowl.

Poultry, eggs and milk have also been contaminated with PCBs.

They are also found in cow's milk and in human breast-milk.

Perchloroethylene, or PCE, which is a widely-used dry-

cleaning chemical in the United States is a colorless, heavy

liquid which has been classified by the EPA as a probable

human carcinogen. Toxics A to Z describes other effects from

PCE exposure. According to them "liver, kidney, and central

nervous system effects have been observed in people exposed

to PCE in the workplace." (p. 413) PCE enters the body

through inhalation and ingestion and through the skin. Like

PCBs, PCE tends to accumulate in body fat and has been found

in human breast milk.

Trichloroethylene, or TCE, which is a colorless,

volatile liquid solvent, is considered a probable human

carcinogen. In animal studies, there was an increase of liver

and lung cancers in rats and mice exposed to the TCE. Other

effects from exposure to TCE include headaches, fatigue,

irritability, memory loss, and depression. Cirrhosis of the

liver may occur from extended exposure. When people who want

a high inhale it, death can occur. According to Toxics A to

Z, "Most of the TCE produced eventually ends up in the

environment. It is widely distributed in the air, water, and

soil of most industrialized nations." (p. 420) The guide also

points out "TCE is the most frequently detected contaminant

of groundwater" (p. 420) and that it has also been "detected

in low concentrations in food such as beverages, dairy

products, fruits, vegetables, edible oils and fats, and

marine fish" (p. 420) According to Toxics A to Z, although

TCE does not cause birth defects it "easily crosses the

placenta.  Measurable amounts of TCE have been found in the

fetus within 2 minutes following maternal exposures." (p.

421) When TCE is broken down by microbes in soil and water,

vinylidene chloride (a suspected human carcinogen) and vinyl

chloride (a known carcinogen), which are more toxic than the

TCE, are formed.

Vinyl chloride, which is a colorless gas used to make

PVC plastic, is also a carcinogen. According to Toxics A to

Z: Vinyl chloride can cause cancer in people following both

inhalation and ingestion. It is known to cause liver, brain,

and central nervous system cancers in people, and it may also

cause human lung cancer, leukemia, and lymphoma. Vinyl

chloride is a mutagen both to animal and human cells.  (p.


Because it is a carcinogen, vinyl chloride is no longer

used as an ingredient in drugs and cosmetics, or as a

refrigerant, an aerosol propellant, or an anesthetic. Other

noncarcinogenic health effects from exposure to vinyl

choloride include headaches, dizziness, nausea, abdominal

pain, liver damage and a bone loss disorder which affects the

fingers, and circulatory changes. According to Toxics A to Z,

"Vinyl chloride can also be found in some municipal drinking

waters and in a variety of foods and beverages, including

alcoholic drinks, vinegar, oil, butter, and mineral water."

(pp. 430-31)

In addition to the halogenated hydrocarbons, polycyclic

aromatics (PAHs) found in sewage sludge are among the most

common toxic organics. An example of PAH is Benzo(a)pyrene,

which is found in coal tars and coal tar derivatives and

asphalt, and is classified as a probable human carcinogen.

According to Toxics A to Z, information from animal tests

show that B{a}P "impairs reproduction in mice by causing

birth defects and reduced body weight of newborn animals."

(p. 236) Other health effects discussed in the guide were

skin lesions from direct contact and bronchitis. B{a}P can

enter the body through inhalation, ingestion, or direct

contact with the skin. It bioconcentrates in food chains.

The inorganic substances in sewage sludge that can cause

harm to humans, animals, and plants, and which are the only

pollutants regulated by Part 503 sludge rule are the toxic

heavy metals--arsenic, cadmium, copper, lead, mercury,

molybdenum, nickel, selenium and zinc. Arsenic, which is used

in the production of boric acid and pharmaceuticals, can

cause brain damage, nervous system damage, gastrointestinal

damage, and skin lesions. A human carcinogen, it also causes

birth defects and genetic damage in test animals.

Cadmium, which is used in industry in electroplating,

battery production, in pigment manufacture, as a plasticizer,

chiefly in polyvinyl chloride, in low levels over a period of

time may cause cancer, kidney disease, neurological

disfunction, diminished fertility, immune-system changes, and

birth defects. It has caused tumors and birth defects in

rats. Inhalation of fumes or dust affects the respiratory

tract and the kidneys.

Copper, which is a gastrointestinal tract irritant, can

be highly toxic. In the copper smelting industry there is an

excess of cancer cases.  Damage to the nervous system and

kidneys have been recorded and jaundice has been observed. In

some cases, the liver has been enlarged.

Lead, which is used in the manufacture of pigments and

lead acid batteries, and is a by product in metal smelting,

can at low levels over a period of time cause brain and bone

damage.  It has caused malignant tumors in test animals. It

is a carcinogen of the lungs and kidney, an experimental

teratogen (birth defects) and affects the central nervous

system. Lead enters the body by inhalation of the dusts,

fumes, mists or vapors, by ingestion of lead compounds

trapped in the upper respiratory tract or introduced into the

mouth on food, fingers or other objects, or through the skin.

Lead is a cumulative poison.  Increasing amounts build up in

the body and eventually a point is reached where symptoms and

disability occur. It affects the red blood cells producing

anemia. It also damages organs or tissues with which it comes

into contact.

Mercury, which is used in the production of chlorine,

caustic soda, electrical apparatus, as a plasticizer, in

metallurgical processes, and in chemical production is a

teratogenic and can cause genetic damage in humans.

Hexavalent mercury is known to cause brain damage and damage

to the central nervous system. In humans it is absorbed by

skin, respiratory and gastrointestinal tracts.

Molybdenum, and its compounds, which are used

considerably in industry are highly toxic based upon animal

experiments. It is a poison through the air, water or food


Nickel, and most of its salts ingested in large doses

can cause intestinal disorders, convulsions, and asphyxis.

Many nickel compounds are experimental carcinogens.  All

nickel contaminating dusts are regarded as carcinogenic by


Selenium, which is used in manufacture of electronics

equipment, steel, pigments, glass and ceramics, is a poison

by inhalation and intravenous routes.  It is an experimental

carcinogen. Longterm exposure may be a cause of amyotrophic

lateral scleroses in humans (Lou Gehreg's Disease). It can

cause "blind staggers" in cattle.  Dust or fumes can cause

serious irritation of the respiratory tract.  Selenium can

react violently with nickel and zinc.

Zinc, is a human skin irritant and effects the pulmonary

system. Zinc salts, such as chromates and arsenates, are

experimental carcinogens.

Although the various toxic organic chemicals and heavy

metals by themselves pose a threat to human and animal

health, another threat comes from the mixture of all of these

toxic pollutants together in sludge. Dr. Donald Lisk of

Cornell University says "the final hazard from sludge use,

therefore, will be determined by the combined effects of all

of these."

Besides toxic organic and inorganic heavy metals, in the

proposed 1989 regulation, the EPA acknowledged a primary list

of 25 pathogens (family groups) in sewage sludge which can

cause serious health problems, including death, when exposed

is through water, air, soil or food.  Most infections start

with flu-like symptoms.

Five pathogens groups listed by EPA are bacteria, nine

are viruses, five are helminths, five are protozoans and one

is a fungi.  The bacteria groups Campylobacter jejuni, E.

coli, Salmonella, Shigella and Vibrio cholerae cause

abdominal cramps, diarrhea, vomiting, fever, chills, malaise,

nausea, headache; Salmonella, Shigella and E. coli infection

can lead to death.  Listeria may be even more deadly, but

like E. Coli, it was not considered to be a problem in 1989.

Among the over 120 different viruses are: 1)

Entroviruses or Picornaviruses (152 species); many of these

will cause pneumonia,  2) Poliovirus (3 species) causes

paralysis, meningitis, fever, 3) Coxsackievirus A (23

species) causes respiratory illness, fever, meningitis;

Coxsackievirus B (6 species) causes same symptoms as A and in

addition myocarditis, congenital heart anomalies and

inflammation of heart in newborns, 4) Echovirus (31 species)

causes inflammation of the heart, spinal cord & brain, 5)

Hepatitis A virus can cause death , 6) Norwalk and Norwalk

like viruses cause mostly diseases of the gastrointestinal

tract, 8) Reovirus, unknown, and  9) Rotavirus causes acute


The five Helminths include worms such as roundworms,

hookworms, tapeworms and nematode worms. In humans, the

worms may end up in the brain where they are untreatable,

as well as in the retina vessels, liver, lung and heart. The

larve cause hemorrhage, inflammation, necrosis in these

tissues.  This causes myocarditis, endophthalmitis, epilepsy

or encephalitis.

The five Protozoans; 1) Toxoplasma gondii causes

pneumonitis, hepatitis and encephalitis, 2) Balantidium is

mild, 3) Entamoeba histolyca forms liver abscess, 4) Giardia

lambia is the cause of severe intestinal problems, 5)

Cryptosporidium causes explosive diarrhea and cramps; it was

first described in humans in 1976.

The one fungi considered by EPA was the deadly

Aspergillus; it causes inflamed tissues in bronchi, lungs,

aural canal, skin and membranes of the eye, nose or urethra.

It may also produce mycotic nodules in the lungs, liver,

kidney and other organs (FR 54-P.5829 & Tabor's Cylopedic

Medical Dictionary).

By 1993, the only reference in the final regulation to

the pathogenic disease organisms in sludge was in the

definition of a pollutant. Another major change in the final

regulation was that the harvesting restrictions on all food

crops, to allow the die off of the disease organisms, was

reduced from as much as 38 months to only 30 days.

The Powell Tate recommendation that one of the

information sheets in the biosolids' promotional kit would

"detail scientific research and assure public health

officials--and --in turn, their constituencies--of the safety

of biosolids (p. 30) was readily adopted by the EPA/WEF.  In

bold capital letters they title their third information sheet


sheet, they claim that "Long-term scientific studies over the

years have consistently demonstrated that biosolids recycling

is both safe and beneficial". Following the recommendation of

Powell Tate, they cite sources that they say attest to the

safety of biosolids recycling.  One of these studies is the

Ohio study.

In 1984, C. Richard Dorn, Chada S. Reddy, David N.

Lamphere, John V. Gaeuman and Richard Lanese, from the

Departments of Veterinary Preventive Medicine and Preventive

Medicine from Ohio University conducted an epidemiologic

study of 47 farms (78 families with 164 persons) receiving

annual applications of treated sludge of 2-10 dry metric

tons/ha/yr and 46 control farms (53 families with 130

persons) not receiving sludge, in which they found the rates

of respiratory illness, digestive illness, or general

symptoms were not significantly different between sludge farm

and control farm residents. The study was published in 1985

in Environmental Research 38, pp.  332-359

There are major problems with this study. First, based

on EPA's defintion of a pollutant, it would have been

unethical as well as illegal to put humans at risk for the

study. In other words the study had to be rigged from the

start.  Second, no farm family would ever knowingly agree to

such a study if they knew there was the slightest

possibilityy their food, water and land could be poisoned

with pathogens, organic and inorganic chemcials.  There

simply isn't enough money in the world for a farmer to take

part in a study which could expose his/her mate and children

to toxic pollutants which could kill them or worse.

The Third problem is the length of the study.  It was

originally set up to last for three years.  Obviously, the

researchers must have decided three years were necessary to

adequately assess the health effects.  If one year would have

been enough, the study would have been set up for only one

year not three.  Only for the first year was there 100%

participation by all the members of the families from both

experimental and control farms.  Thirty-five individuals from

the sludged farms and 44 individuals from the control farms

withdrew.  Thirty-six sludge farms completed 2 years and 13

completed 3 years.  Thirty-seven control farms completed 2

years and 13 completed 3 years.  When any subjects are lost

from a study, the results of the study are called into

question. According to Walter R.  Borg and Meredith D.  Gall,

authors of Educational Research (1983), "The subjects lost

will generally be different from the ones who remain with the

study until its completion. The nature and magnitude of these

differences, and therefore their effect upon the research

results, are difficult to estimate." (pp. 205-206)

The major flaw in the study was that it failed to

include any information on the sludge itself. There is no

data on the type of treatment to reduce pathogens or the

chemical content of the sludge.

This study, which was sponsored by the EPA, looked only

at the short-term one year effects of exposure to sludge.  It

did not address the subchronic or chronic health effects to

people exposed to sludge--immune system impairment, cancer,

and endocrine-disruption. So EPA/WEF's claim that the Ohio

study attested to the safety of sludge is not substantiated

by the facts. The researchers recognized the limitations of

this study in predicting health risks associated with sewage

sludge.  According to them:

The absence of observed human or animal health effects

resulting from sludge application in this study of Ohio

farms was associated with low sludge application rates

which were in accordance with Ohio and U.S.

Environmental Protection Agency guidelines. Caution

should be exercised in using these data to predict

health risks associated with sludges containing higher

levels of disease agents and with higher sludge

application rates and larger acreages treated per farm

than used in this study.

Among the sources that WEF/EPA cited, who definitely

were not unbiased, were Chaney of the USDA, who supports land

application of biosolids, and research done by the Water

Environment Research Foundation (WERF) of the WEF itself.  In

their sales hype, various WEF spokespersons for the promotion

of sewage sludge (biosolids) claim that there is a consensus

in the scientific community that the use of sewage sludge is

safe for both land application and in distribution and

marketing sludge products. However, contrary to what they

claim, in the scientific community there is considerable

controversy and uncertainties about the safety of sewage


One of the scientists who disputes the claim that sewage

sludge in land application is safe is Dr. Stanford Tackett.

Most of Dr. Tackett's academic career has been devoted to the

study of lead and its harmful effects on humans, particularly

children, and its spread into the environment. Dr. Tackett's

expertise was recognized by the EPA. In 1991 he conducted a

study for them to find ways to reduce the lead concentration

in drinking water. According to Dr. Tackett there is no

consensus in the scientific community that sludge is safe. On

the contrary, he says, "A large body of scientific

information has been accumulated by analytical chemists,

medical researchers, toxicologists, and children's health

experts which indicates that the spreading of sewage sludge

as a fertilizer is a potentially dangerous practice."

He adds further that "while the one-sided research

collected by EPA purports to show that sludge is safe, there

are many research reports and individual case studies that

show exactly the opposite."

Another scientist who questions the safety of sewage

sludge is Dr. Donald Lisk of Cornell University's Toxic

Chemicals Laboratory in Ithaca, New York. He disputes the

claim by the proponents for sludge use on land that a "well-

engineered" sludge is safe. He says, "The concept of a "well-

engineered" sludge is a myth. There is no sound scientific

basis for limiting levels of potential toxicants in sludge

since we do not know the identity of most of them." (p.3)

In a court case in Rappahannock Virginia's Circuit

Court, the lack of consensus in the scientific community on

the safety of sewage sludge was evident in the testimony of

scientists for both the plaintiffs and defendants. In the

Rappahannock County court case the county was sued by several

local farmers backed by a sludge hauler to overturn a county

ordinance adopted by the county board of supervisors to

modify the zoning code and prohibit the use of sewage sludge.

Judge Joshua Lowell Robinson ruled in favor of the county

stating that the county board of supervisors had the right to

determine how sludge was to be disposed of in the county.

Furthermore, he expressed concern about the hazards from the

chemical content of the sludge.

When Hugh Kaufman, whistleblower for the EPA, and

TriStar Television appealed a defamation judgment of a lower

Texas court, which awarded Merco Joint Venture nominal

damages of $1.00 against both Kaufman and TriStar and

punitive damages of $500,000 against Kaufman and $4.5 million

against TriStar, the United States Court of Appeals, Fifth

Circuit in New Orleans reversed the lower court decision.

They rendered judgment for Kaufman and TriStar because

evidence at trial suggested that experts had yet to reach a

consensus on the safety of land application of sludge.

In the spring of 1994, a television show produced by

TriStar focused on the sludge shipments arriving from New

York to a 128,000 acre ranch in Sierra Blanca, Texas.  In

1992, Merco (under contract with New York City to dispose of

up to thirty percent of the city's sewage sludge), purchased

the 128,000 acre ranch in Sierra Blanca for a disposal site

for the sludge shipments from New York which started arriving

in 1992.  TriStar's segment "Sludge Train" was broadcast on

August 2, 1994. Hugh Kaufman, the whistleblower for the EPA,

was a guest on the show. Merco, upset by the broadcast, sued

Kaufman and TriStar for what they said were defamatory,

disparaging and false allegations. A lower Texas court ruled

in favor of Merco.  When the Court of Appeals Fifth Circuit

reversed the lower court decision and rendered judgment for

Kaufman and TriStar, they found:

The conclusion the evidence at trial suggests is that

experts have yet to reach a consensus on the safety of

land application of sludge. Merco, itself, conceded land

application of sludge was controversial. At best,

Merco's evidence proved certain experts believed sludge

is safe. It did not, however, prove TriStar and Kaufman

knew or should have known their position evidenced by

the TV Nation broadcast, was false, or that it was in

fact false. (p. 4)

   Kaufman's statements that Merco was an "illegal

haul and dump operation," and that "the people of Texas

are being poisoned," were shown at trial to be Kaufman's

honest beliefs and were not so without basis as to

constitute reckless disregard of the truth. Kaufman

testified to several aspects of the Merco operation he

found questionable, and noted instances when Merco had

failed to comply with various regulations. (pp. 4-5)

Kaufman professed his sincere belief that the land

application of sludge is dangerous, and will eventually

be proved harmful. His figurative reference to "poison"

is hyperbolic, but exaggeration does not equal

defamation.  Merco repeatedly claims experts and

agencies have stated sludge is safe, and argues those

opinions prove Kaufman should have known his statements

were false. However, these expert opinions are merely

that--opinions. Moreover, because an "expert" endorses a

certain practice does not mean all reasonable debate on

the merits or safety of that practice is foreclosed.

(p. 5)

   Sekoff's voice-over comment that sludge contained

"high levels of lead, mercury, and PCBs, likewise failed

to meet the standard of actual malice. The vagueness of

the term "high levels" makes Merco's burden of proving

defamation even more difficult.  As well, the statement

made no particular reference to Merco sludge, referring

instead to sludge in general. Kaufman, who originally

made the statement, based this assertion on numerous

articles and reports questioning the safety of sludge

and its contents. There was adequate support for the

statement. (p. 5)

Most scientists are not independently wealthy and able

to conduct research in their field without sponsorship by

grants or employment by government agencies, corporations,

private foundations, and university research centers.

Scientists, who obtain grants or are employed by the EPA know

at the beginning that the results of their research project

is expected to support the sponsor's special interest--the

beneficial use of sewage sludge (biosolids).  In a memo of

February 28, 1995, John Walker of the EPA listed goals that

were to be discussed at a meeting with the USDA for better

research and risk assessment.  One of these goals was to

"provide for more higher quality biosolids [sludge] research

by municipalities, universities, and others." For this

purpose the EPA had "earmarked some 104 (b)(3) funds aside

for assisting in accomplishing this research." Through their

grant program, awarded mostly to agronomists and soil

scientists, EPA has ensured that they will have scientific

spokespersons for their public relations campaign. Dr.

Tackett calls EPA's sludge science "selective science". He


EPA has supported the land spreading of sewage sludge

for over 25 years through manipulation for research

money and the application of "selective science."

Millions of dollars have been made available through EPA

and other federal, state, and local agencies, for

"beneficial use" research.  Agronomists and other soil

scientists have had a virtually unlimited money pool

available to conduct the "beneficial use" research.

Toxicologists, public health scientists and medical

researchers have not had a similar money pool available

to study potential dangers and adverse health effects of

sewage sludge.

According to Dr. Tackett, the beneficial use scientists

are also well represented on scientific committees.  He says,

"It is no wonder then that the scientists selected by the EPA

to serve on sludge advisory committees are the "beneficial

use" researchers, and the only research reports they deem

acceptable for the purpose of adopting new sludge spreading

regulations are from the "beneficial use" studies."

One of EPA's own scientists lends credence to Dr.

Tackett's charges of selective science. David L. Lewis,

Ecosystem Research Division, EPA National Exposure Research

Laboratory in Athens, Georgia in an article in Nature in June

27, 1996 stated:

Historically, the number of EPA professionals educated

in the life sciences has been low compared with those

trained in the physical sciences, and has been

decreasing in recent years. Reflecting this disparity

only a third of the internal grants awarded by ORD

{Office of Research and Development} support projects in

the biological sciences. (p.  731)

According to Don W. Cox, President of Oklahoma Wildlife

Federation, there is a definite conflict of interest when a

university receives a grant from any sludge source. In a

letter to the Chairman of the U.S. House of Representatives

Subcommittee on Conservation, Credit and Rural Development

dated April 16, 1992 he wrote:

A common practice at the present is to offer a nearby

state university soil science department a "grant" to

research the sludge application program if the program

is accepted by the community and the regulatory agency.

The soil scientists then begin making public statements

as to the beneficial nature of sludge. There is a clear

conflict of interest in such cases. (p. 7)

Powell Tate  suggested that Land grant colleges and

agricultural schools would be good sources for regional

spokespeople to help WEF members with their educational

campaign. Powell Tate spoke with the National Association of

State Universities and Land Grant Colleges to assess its

interest in the issue. The organization reported that some of

its members may be studying biosolids land application and

that the group would like more information. A strong

recommendation of Powell Tate was "that WEF meet with the

organization before the campaign begins to seek its active

involvement." (p. 38)

When Powell Tate conducted research on appropriate

spokespeople for the Water Environment Federation, they

compiled a list of indiviuals who they thought might serve as

spokespeople. These were listed in Appendix B of their

report. Missing from the list was Dr. Terry Logan of Ohio

State because they said "we have tried not to include

individuals currently serving in that role, such as Dr. Terry

Logan of Ohio State." (p. 34)

Jane Beswick, Coordinator for Coalition for Sludge

Education, in a letter to Dr. Allan Rubin of the EPA

questioned the vested interests of some of the beneficial use

sludge scientists, like Dr. Logan, who are either employees

of universities, receive research grants, perform research

and/or have a financial interest in the industry.  According

to Jane, Dr. Logan was Co-chair of the U.S.  EPA Peer Review

Committee, helped research N-Viro soil (a sludge product),

and was instrumental in establishing the "clean" sludge

concept. He was also a paid consultant ($2,400/month) and

stockholder of N-Viro, International. He was recently named

president of Pan-American N-Viro.

Another example of a scientist with a conflict of

interest was William Sopper. When he gave testimony in favor

of sludge application to land at a public hearing at the

State House Conservation Committee in Indiana, he represented

himself as an unbiased source--a professor of hydrology at

Penn State.  It was later brought out that he had a financial

interest in the land application of sewage sludge because he

had been on the payroll of Modern Earthline Co., a now

defunct hauler of Philadelphia sludge to Glen Campbell.

Not only are we being duped by selected biased

scientists who assure us that land application of sewage

sludge is safe, but also by WEF's so-called "water quality

professionals". Research by Powell Tate revealed that "water

quality professionals" are considered as trusted messengers".

They say since the research did not probe further as to whom

respondents considered "water quality professionals," we can

promote our spokespeople as the "water quality professionals

to be trusted." (pp. 9-10) Their advice was that WEF members,

therefore, should be encouraged to reach out to the public as

"water quality professionals" (rather than "waste treatment

specialist" or a similar title). They say "given the

vagueness of this term {water quality professional), we see

no reason why WEF members should not fully adopt this term in

referring to themselves and in all materials produced for the

campaign..." They add further, "we suggest that the WEF

(spokesperson) be introduced as a water quality professional

with XYZ company." (p. 33)

They also recommended "that WEF, through its members,

recruit at least 6 regional spokespeople to be trained in

media and presentation skills and aggressively marketed by

WEF with the media in their respective regions as a "water

quality professional" knowledgeable in the field of biosolids

recycling." They suggest that "once trained, these

individuals can be scheduled for editorial board visits,

media interviews, meetings with community leaders and

appearances at public forums in their regions." They say "An

ongoing outreach campaign to the media using these

individuals is essential in communicating messages to

gatekeeper audiences and, through them, the general public".

(pp. 33-34) These spokespersons can be used for "medical

interviews, to byline articles for placement in newspapers

and journals, to visit and brief editorial boards, to appear

at conferences and on panel discussions, and to testify, as

appropriate, at regulatory and legislative hearings." (p. 31)

Upon recommendations by Powell Tate, spokespersons are to be

trained specifically on "how to deal with the media, to

communicate certain messages, to handle different types of

media interviews and to make presentations." They suggest

that, "Should funding allow, consideration might also be

given to recruiting one national spokesperson who can

represent the broader, national interest on this issue."

By changing the name sewage sludge to biosolids and

by claiming that biosolids recycling is good for the

environment, the EPA/WEF public relations campaign has

been able to enlist the support of certain environmental

groups whose members spout the EPA/WEF propaganda. According

to Stauber and Rampton, Sarah Clark, formerly of the

Environmental Defense Fund, claims that sludge "is the best

means of returning to the soil nutrients and organic matter

that were originally removed. It is recycling a resource just

as recycling newspapers or bottles is." According to these

authors, "Some environmental activists with Greenpeace and

the Citizens Clearinghouse on Hazardous Waste have warned

about the dangers of sludge, but most groups have bought into

the argument that sludge farming is the least offensive way

to deal with the problem of waste disposal."

The roles the targeted environmental groups such as the

Environmental Defense Fund are to play in the public

relations campaign was spelled out in the Powell Tate

Communications Plan. They suggest that "WEF request that the

environmental partner add its name to the environmental

information sheet in the kit." They say this will give the

information added impact and credibility." Environmental

groups such as the Coastal Conservation Association whose

focus is on ocean-related issues, especially, are prime

targets.  Powell Tate believe they should be "most receptive

and may be recruited to help gain the support of other

organizations." (p. 10) They say "it is in this group's (CCA)

interest to promote biosolids recycling if only to guarantee

that biosolids are never again deposited in the ocean." They

add "Obtaining an endorsement from the group for biosolids

recycling will help with other environmental groups (strength

in numbers) and can be used to spread word about beneficial

use with "green" individuals.

A June 15, 1994 WEF Campaign Update on Biosolids

Recycling detailed how well WEF had followed the Powell Tate

Communications Plan for Biosolids. These included:

Eight regional and one industry spokesperson have been

selected and trained. Staff is working with Biosolids

Acceptance Teams (BATS) on pilot campaigns in regions

where spokespeople are located.

Over 400 information kits and videos have been sent to

the Federation's biosolids network, as well as to

environmental, public health and agricultural

organizations.  General media and a select agriculture

mailing list also were mailed kits.  Staff continues to

fill requests for materials based on interest in

establishing a community campaign.

In addition to the training spokespeople completed last

Spring, media training sessions have been offered at

five WEF regional meetings. A special workshop is being

offered at the International Biosolids conference June

19th.  Several BATS (Pacific Northwest and Georgia) are

organizing media training sessions at their annual


Stauber and Rampton found in the research for their

book, Toxic Sludge Is Good For You that the EPA's PR strategy

was "first outlined in a 40-page report published in 1981

with a classic bureaucratic title: Institutional Constraints

and Public Acceptance Barriers to Utilization of Municipal

Wastewater and Sludge for Land Reclamation and Biomass

Production". They say in this report that "the ICPABUMWSLRBP

warns that projects may be blocked by small local groups.

Citizens who 'feel their interests threatened' may 'often

mount a significant campaign against a project.' They add "To

counter this opposition, ICPABUMWSLRBP advises projects

advocates to choose a strategy of either 'aggressive' or

'passive' public relations." According to the ICPABUMWSLRBP

report, Stauber and Rampton say "Aggressive public relations"

uses glossy brochures describing the project; open public

meetings, presentations to specific interest groups;

presentation of films about similar projects; local media

coverage; technical education campaigns for the public and in

schools; establishment of a hotline for quick response

questions and presentation of material stressing community

benefits from the project." The Powell Tate public relations

communication plan, for the most part, advocates an agressive

strategy similar to that of the ICPABUMWSLRBP. With the

tremendous push for the total public acceptance of sewage

sludge by the year 2000, many local groups over the country,

who are attempting to ban land application of sewage sludge

in their communities by alerting residents of its adverse

effects on humans and animals, are facing a highly visible

aggressive public relations campaign as recommended by Powell


In contrast to the aggressive campaign, the passive

campaign, say Stauber and Rampton, makes " little effort to

reach out to particular segments or constituents of the

public. Rather, information about the project {is} made

available for individuals and groups which made the effort to

obtain it."  According to these authors, "This secretive

approach works best in small, rural communities 'where the

application site is relatively isolated.'"

An example of the passive approach was given in a panel

presentation at the Citizens Forum on Environmental and

Health Concerns from Landscaping of Sewage and Paper Mill

Sludges on November 15, 1997 in Concord, NH, by Steven

Schiller. Steve is a resident of Newbury, New Hampshire, a

small town of about 1200 people. He related to the panel how

he and other residents were unaware that land reclamation of

a sand pit using sewage sludge was even occurring in their

town until the dump trucks came rolling in early one morning:

In November of 1995, my wife was up early. She was a

baker at the time, so she had to be at work at 5:00 in

the morning.  She was up before dawn at four o'clock

a.m., and we live in a town with a road that's about as

wide as that table. And she heard a strange rumbling

sound and she thought we were going to get a storm. And

the sound got louder and louder down 103 and then it

turned onto our little road, and she had lost count of

the number of large 22-wheel dump trucks that came

rumbling down our street with their lights off at four

o'clock in the morning. And they turned across the

street from our house down a dirt road into a sand pit.

So my wife came in at four in the morning and she woke

me up, which I don't like at all. And she said,

"Somethings going on in the pit across the street." And

I said, "yeah, uh huh.

And I didn't give it much thought, until about a month

later when I got up to go to work and the sky above my

town was blue-black and the smell was so overwhelming

that my daughter was ill, my neighbors were ill...

And then I came to find out that the guys that work at

the state road department, also across the street from

my house, had all taken sick that day. And the people

started calling our selectmen to find out what was

burning in the pit. "Oh, nothings burning in the pit."

"Well, what's going on in the pit?" "Well, there's some

land reclamation going on in the pit." "Oh, what's land

reclamation all about?" Well, that's when we found out

about the federal regulation to reclaim land that's been

strip mined... we called BFI; they came around and reassured

everybody in the community. Of course, they hadn't told

us they were going to do this, and if my wife hadn't

been up at four o'clock in the morning, we wouldn't have

known it was done.

Steve voices how he and other residents felt about the

secrecy surrounding the sludge reclamation project by the

complaint they directed to BFI.

"No we don't like it because we don't know what's in it,

and you're not telling us what's in it, and our selectmen

don't know what's in it, and you didn't tell them what's

in it, and you're telling me, oh, it's an acceptable

level of risk.  Who's taking the risk? Are you taking

the risk, BFI?

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