Sludge permitting policy is a major concern across the country, Bynums say
Re: July 28th Hearing -- Sludge War in Jefferson County
Georgia's EPA sponsored toxic sewage sludge farmland disposal permitting policy is not just
a local problem, it is a major concern for everyone in the state and nation. The policy not
only allows pollution of the land with chemical and biological agents, it allows the
contamination of the air, water and food crops. Because EPA and permit writers have
immunity by law, they are putting the farmers and their neighbors at risk under an
environmental law exclusion. Toxic pollutant runoff from a farm is a non-point source of
pollution allowed by law. However, if farmers will not take the toxic sludge as a fertilizer, it
must be properly disposed of in a highly regulated landfill where pollutant runoff is
prohibited. With 160+ million acres of federal land, EPA says we are running out of landfill
space and those we have may contaminate groundwater. Studies show the concern is the
severe health and environmental effects associated with mismanaged landfills.
How could a permit writer consider permitting a farmland toxic sludge open dump site when
the EPA Administrator has information on file which proves that exposure to the toxic
chemicals and biological agents in sludge either through direct contact, or indirectly through
the air, water or foodchain will/could cause death, disease, cancer, physical and/or mental
disorders and birth defects? Even though EPA promoted the use of toxic sludge as a safe
fertilizer to farmers and the public, it did not hide this information from the permit writers. The
statement can be found in the Clean Water Act as well as 40 CFR 503.9(t).
The permit writers are taking advantage of the fact that farming is a very hazardous
occupation with a high incidence of cancer and respiratory diseases caused by farm related
chemical fertilizer, pesticides and fungal biological hazards. Farmers use caution in handling
these hazardous materials. However, farmers have not been told of the more deadly toxic
chemical and biological pollutants in sludge sold or given to them as a fertilizer. Early1980s
Cornell research found that this extremely toxic mixture in sludge would quickly kill laboratory
mice. What EPA focused on was the researchers finding that the cause of death could not
be determined from pathological evidence. Therefore, the scientific consensus was that it
would be virtually impossible for a farmer or his neighbors to prove any harm from sludge.
This style of scientific consensus was used against Washington dairy farmers Ray and Linda
Zander when their farm was destroyed by groundwater contamination from a neighbors
farmland sludge dump site. There were human and cattle deaths on the Zander farm as well
as bacterial, metal poisoning and neurological health damage.
In Missouri, Ed Roller's dairy farm was also destroyed by toxic pollutant runoff from a sludge
site killing a major part of his herd. Eighty acres of the Alice Minter Trust farm in Kansas City
became so contaminated from the toxic polluted (Salmonella and E coli) runoff from the city's
sludge site, the city got a court order preventing any visitor (friends or otherwise) from
gaining access to that part of the farm. The 80 acres had to be sold to the city at a fire sale
price to save the rest of the farm.
In Vermont, Bob Rune's dairy herd was almost destroyed because of poisoned fodder grown
on sludged soil. His cattle stopped dying when he changed to non sludge grown fodder.
In Georgia, Boyce and McElmurry dairies had dead animals piling up after sludge was used
as a fertilizer on their farms. Justice hasn't been served yet.
When California dairy farmer Jane Biswick opposed the sludge permitting process in her
county, EPA's sludge expert sent threatening notes and the regulators ran her out of
business. Testifying before Congress did Jane no good.
This affects everyone. Dr. David Lewis "investigated public complaints and concluded that
irritant chemicals associated with volatile chemicals and dusts blowing from [sludge] treated
land (e.g., bacterial toxins, lime, organic amines) may cause nearby residents to be more
susceptible to infections. Lewis documented an outbreak of Staphylococcus aureus among
individuals exposed to a Pennsylvania land-application site and attributed the infections to
secondary exposure routes (animal-to-human or person-to-person)." "The prevalence of S.
aureus infections in this study was approximately twenty-five times higher than infections
among hospitalized patients, a recognized risk group for S. Aureus" Lewis studies include
several deaths as a result of exposure to sludge.
Studies show the toxic pollutants will also be taken up by food crops. Between 1990 and
1997 food poisoning incidents exploded from 6.5 million to 76 million cases annually. You
and your children may also become victims through the deadly toxic chemicals and biological
agents in unlabelled Class A sludge compost and soil amendments purchased for your lawn
The web site www.deadlydeceit.com was created to focus political attention on the subject.
Permit writers should not have immunity to spread death and destruction in the environment
based on this type of deadly deceit. There are two free books on the web site documenting
the corruption and harm caused by sludge.
Jim Bynum and
Gail Bynum, Ph.D.