Chapter Three
DISINFORMATION
The NRC Committee acknowledges the public relations
nature of the public perception study when it states;
"The focus of this study is on the use of treated
effluents and treated sludge in production of food
crops, and no comparative assessment is made of the
economics of other use or disposal alternatives for
sludge and wastewater." (p. 152)
Yet, it does imply that sludge is safe based on
comparative studies. As an example, the report suggested
that the ocean dumping ban was a result of a public
perception problem, "The public reaction in 1988 to the
appearance of medical wastes along New Jersey shores
(Spector, 1992) led to the enactment of the Ocean
Dumping Act (P.L. 100-68) that included a ban on ocean
dumping of sewage sludge." (p. 152)
The NRC Committee quoted a New York Times reporter,
as a scientist. The June 29, 1992 article was titled,
"New York ending ocean dumping, but not problems."
Furthermore, according to the NRC Report, "...., it
is difficult for the public to understand that the
application of sludge on cropland is safe when ocean
dumping of sludge is prohibited even though the major
reason for prohibiting ocean disposal of sewage sludge
had to do with excess nutrient loads on marine
ecosystems rather than toxic pollutants or beach safety
concerns." (p. 161)
There are a number of major problems with these
statements on ocean dumping: (1) the Public Law was
actually (P.L. 100-688), (2) the EPA tried to force New
York City to end the ocean dumping in 1981, however, the
courts ruled against the EPA, (3) Congress and the
Senate reversed the court ruling in 1986 and New York
City was forced to move its sludge dump site from the 12
mile site to the 106 mile site, (4) "Adverse impacts at
the site at least in part contributed by sludge dumping
include: bacterial contamination and closure of
shellfish areas; elevated levels of toxic metals and
organohalogens in bottom sediments in and near the site
including known fishing areas and within five nautical
miles of coastal beaches; community changes in relative
abundance and diversity of species; sublethal toxicity
effects in economically valuable species;
bioaccumulation of certain metals and organohalogens in
fish and shellfish" (Senate Report No. 199-431), (5)
Furthermore, according to the Senate Report, "With the
onset of large scale dumping of sewage sludge at the 106
mile site in 1987, fishermen began to complain of
significant decreases in catches and incidences of
diseased fish which were previously not found at these
depths. Some of the diseased fish have a shell disease
which is associated with sewage sludge and pollution in
coastal waters. This disease was found around the 12
mile site.", (6) At that time (1987), there were no
documented scientific studies to produce evidence of the
damage by sludge at the 12 mile site and according to
the Senate Report, "Scientists are just beginning to
explore the impacts that sludge dumping may be having on
marine resources in the area potentially effected by
sludge dumping at the 12 mile site.", (7) The Bill also
redefined "sewage sludge" (P.L 95-153- 33 U.S.C.
1412a(d)) to mean any solid, semi-solid, or liquid waste
generated by a wastewater treatment plant. Moreover,
"EPA would be precluded from determining whether or not
the sewage sludge may unreasonably degrade or endanger
human health, welfare or amenities, or the marine
environment, ecological systems and economic
potentialities. These changes are made to reverse the
1981 District Court decision which allowed ocean dumping
of sewage sludge to continue. In that case, the Court
found that sludge dumping by New York City had not
"unreasonably degraded or endangered human health.....",
(8) two of the main points expressed in the Senate
report was, "it is difficult to monitor the harmful
effects of dumping sewage sludge in the ocean and there
is no way to clean up dumped sludge if such sludge is
determined to be harmful in the future."
While the Committee, like the EPA, does not know
the extent of sludge contamination in food, nor the harm
it can do, they forge ahead in their attempt to assure
the public that sludge used on crops is safe. The
Committee acknowledges in an offhand manner that there
could be problems, especially with PCB's. "While the
committee concluded that these organic pollutants in
sludge were not likely to present a risk to consumers of
food crops, public concern have been raised by the fact
that even a small percentage of sludges have
concentrations of certain pollutants (e.g., PCBs) that
exceed a risk-based limit of acceptability." (p. 161)
The NRC Committee acknowledge in the Preface its
"hope" that the report would influence (be useful to)
the food processors, states, and municipalities. Yet,
it now qualifies its conclusions by saying it is not
likely the toxic organics will present a risk to
consumers even though a small percentage of sludge have
pollutants that exceed a risked based limit of
acceptability. The question remains, is the crops grown
on sludge fertilized soil safe for human consumption?
In reality, the only place this report would be
useful to the food processors and sludge dumpers, is in
a court of law, when they have to defend the use of
sludge on crops. The scientific reputations behind the
report would be very impressive when presented to a
judge and jury. According to the report, at least
forty-six scientists were involved in the Committees
which developed the report or reviewed it. In Court, a
victim would be blamed for his/her own health problems,
because, (1) the top "scientific agency" in the United
States concludes that sludge use is safe for use on
crops and will not damage anyone's health, (2) there is
no disease caused by sludge use that can not be blamed
on poor sanitation measures in handling the food, in a
restaurant or at home, and (3) as a last resort, the
victim improperly cooked the food.
The biased nature of the report was reinforced when
the scope of the NRC literary review was stated, "(1)
the historical development, rationale, and scope of
practice of treating municipal wastewater and sludge in
the United States; (2) wastewater treatment technologies
and procedures for agricultural use of these materials;
(3) effects on soils, crops production, and ground
water; (4) public health concerns about microbiological
agents and toxic chemicals; (5) existing regulations and
guidelines; and (6) economic, liability, and
institutional issues".
While all six of the areas are legitimate concerns
of the public and food processors and definitely
required in an "independent study of the safety and
practicality of the use of these materials for the
production of crops for human consumption", the NRC
literary review now stated, the original stated purpose
of the committee did not include an independent risk
assessment of possible health effects. "The committee
was not constituted to conduct an independent risk
assessment of possible health effects, but instead to
review the method and procedures used by EPA in its
extensive risk assessment, which was the basis for the
Part 503 Sludge Rule". (p. viii)
That review apparently did not include EPA's risk
assessment model for drinking water contamination
exposure, which was calculated by estimating the amount
of contaminate carried off all the sludge sites in each
State by rain water and dividing that into the total
surface water of each State (FR 54, p. 5781).
Furthermore, the EPA model doesn't consider well
water used by farmers. Since the research data was only
based on one application of sewage sludge there could
have been little or no data on how much of the toxic
heavy metal pollution would get into the ground water.
Therefore, under the EPA's and NRC scientific rules, if
there is no documented research, there can not be a
problem. But it is a problem for many farmers near
sludge application sites; well water is their only
source of water. Furthermore, no research was done on
the effects contaminated forage or water might have on
farm animals or wildlife. Yet, the EPA has documented
that high nitrates (nutrients in sludge) in forage will
kill farm animals.
In effect, it would appear, the purpose of this
report was a public document to evaluate if the EPA's
estimated 501 cases of sickness or death annually was
reasonably accurate, based on the methodology used in
the risk assessment. Not only that, if the NRC
Committee was not going to do an independent risk
assessment of possible human health effects from sludge
used on crops, and it didn't review the final results of
the EPA's risk assessment methods and procedures (levels
of toxic and hazardous substances were increased in the
final regulation), then why would it assure the food
processors and public that the use of sludge on crops is
safe? Furthermore, how could it legally comply with
its mandate to report to the government that sludge used
on crops was safe? Particularly, when the report
indicates that the effluent (clean water) from a
treatment plant could contaminate groundwater when used
for irrigation purposes and had caused documented
outbreaks of disease in the general public.
The NRC summary of the report was that sludge is
safe for use on crops because, "There have been no
reported outbreaks of infectious diseases associated
with a population's exposure-either directly or through
food consumption pathways-to adequately treated and
properly distributed reclaimed water or sludge applied
to agricultural land." (p.95) What does the NRC
Committee mean by, "adequately treated and properly
distributed."
The NRC Report claims that; "Treatment processes
are also available to effectively reduce the
concentration of pathogens in sewage sludge to levels
safe for direct contact. Some examples include lime
treatment, heat treatment, drying and composting (EPA,
1992b)." (p. 90)
Yet, the NRC Report acknowledged, "There are
instances in sludge processing, such as composting, in
which the coliform levels cannot be satisfactorily
reduced even though there is reason to believe that the
sanitary quality of the material is otherwise acceptable
(EPA, 1992b; Skanavis and Yanko, 1994)....Many of the
parasites of concern exist in the encysted stage outside
of the human or animal intestinal track, and are quite
resistant to chemical and physical disinfection in this
form." (p. 94) In effect, "adequately and properly
distributed" is a scientific disclaimer, because land
application and site restrictions are a part of the
treatment process to control pathogens.
The NRC Report acknowledges the problem in the
summary:
"The main thrust of any management strategy is reduction
of concentrations of pathogens to acceptable levels.
This reduction can be achieved by treatment prior to
land application or, as an alternative in the case of
sludge and reclaimed water of lower sanitary quality,
crop restrictions and management of the application site
to restrict human and grazing animal contact during the
time required for pathogens to decay to acceptable
levels." In effect, the basic premise that sludge is
safe for use on crops is dependent on; "Two prime
considerations in evaluating any management scheme are
the ability to effectively monitor for treatment
efficacy and the reliability of the process used to
effect pathogen reduction." (p. 97)
There is a serious problem here, Congress has
passed laws to protect the environment and human health
because sludge dumping has been shown to be dangerous
when exposed to the environment. Yet, the EPA guideline
was published as a scientific regulation under the Clean
Water Act based on limited or anecdotal evidence, and
now the NRC Committee has led the public into assuming
that all necessary testing and scientific study
documentation was done to assure the safety of public
health and the environment and the NRC Committe are
quoting a badly researched newspaper article as a
scientific study.
Not only that, but the EPA only plans to study the
effects of sludge dumping in round two of the sludge
regulating process. At some future date, it will
consider; leaching, surface runoff, soil binding
capacity, and ecological effects of organic and
inorganic constituents, as well as pathogens, and the
effects on wildlife (FR 58-pp. 9275-76).
What about Human Life? The NRC committee did not
address the issue of the effects of sludge on human
life, which is not surprising. Actually, according to a
memo dated 12-29-1994, by EPA's John Walker and Bob
Bastian, the EPA has a working agreement with the Water
Environmental Federation (WEF) for a public relations
campaign to debunk all the horror stories associated
with sludge dumping. The EPA even named the writer to
be hired and since that time has given the WEF 1.2
million dollars in federal grant funds to support the
campaign.
It appears to be a very unusual coincidence that
the EPA is funding a public relations campaign through
the WEF, to promote the use of sludge on crops, and both
entities are funding the NRC study, which concluded that
sludge is safe for use on crops.
Furthermore, according to a memo from EPA's Robert
E. Lee to EPA's John Walker and Bob Bastian, dated Oct.
17, 1994, the public relations campaign funding for the
WEF would come from the EPA 104 grant program which was
restricted to "...establish national programs for the
prevention, reduction, and elimination of pollution..."
However, "Areas that we had considered using these funds
include: 1. Odor Control Manual, 2. Sludge Horror
Stories, 3. Biosolids Technical Assessment, 4.
Management of Class B, 5. Arid Lands, 6. PCB's in
Biosolids...What about one with a water shed
twist....Ways to utilize biosolids in water sheds to
mitigate other environmental problems...Bob B. maybe we
should put one or some $ in for the wetlands work in
watersheds also." The WEF proudly announced the latest
$655,000 EPA research grant in a press release dated,
March 15, 1996.
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Review of National Academy of Science's (NAS) 1996 literary review report by
its National Research Council (NRC) Committee :
"Use of Reclaimed Water and Sludge in Food Crop Production"
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