The paper concludes that sludge can not be safely disposed of on farmland because: 1) only 28 out of 400 toxic
pollutants are proposed for regulation, 2) 15 out of 25 toxic inorganics on the superfund list are not included, 3) Thirty-
three pollutants considered hazardous for land disposal are not included.

The only Regulated Pollutants in Part 503 where those Eligible for a Removal Credit

The new laws should stop intrastate shipment of biological contaminated sludge and the Agricultural Bioterrorism Act
should stop the dumping of sludge on farmland. IF THE BIOLOGICAL AGENTS ARE DANGEROUS IN A

In spite of its own research, EPA said it did not consider any of the cancer causing hazardous metals in sludge to be
cancer causing agents for the risk assessment.

Rather than giving the farmer an honest chance at survival, EPA put together a public relations campaign to change
public perception about the dangers of handling pathogen contaminate sludge/biosolids.

A recent study (63) indicated that rats consuming cabbage and beets grown on sludge^amended soil produced urine
which was mutagenic to TA98 in the presence of a metabolic activating system. Thus, it seems possible for the
mutagenic components of sludge to be transported through the crops grown on it.

In general, the densities of microorganism-containing aerosols were higher at night than during the day.

Agricultural Bioterrorism Protection Act of 2002
This rule is intended to prevent the misuse of select agents and toxins, and thereby reduce the potential for those
pathogens to harm humans, animals, animal products, plants or plant products in the United States.

Adopted Policy: In the absence of effective local and state regulations, which implement a viable bio-solids
management program in place, NACo urges Congress to support increased regulation of the land spreading of bio-
solid residuals or sludge and further urges Congress to appropriate sufficient funds so as to not create an unfunded
mandate on local governments.

Alan Rubin - EPA's Super Salesman Retired
"It's time we looked at direct exposure," Ruben said. "We have in the past concentrated on contaminates in the food

Recently, the newest concern of recycling wastewater is the presence of chemicals such antibiotics, endocrine
disrupters compounds, and personal health care products. Endocrine disrupters, which interfere with the body's
natural ability to produce, release, transport, metabolize, bind and eliminate hormones in the body, have been
observed in wastewater discharges therefore in water bodies all over the world.

Antibiotic Resistants -- Genetic transfer of toxin producing genes between bacteria.

ATSDR, a federal public health agency of the U.S. Department of Health and Human Services, evaluates
the human health effects of exposure to hazardous substances.

Avian flu H5N1 virus
Bird flu virus in sludge/biosolids spread on farmland and home lawns will make an interesting scientific
experiment for health departments

Bacteria - Heterotrophic in sewage sludge biosolids, reclaimed water & drinking water

Bacteria Index: Most bacteria have become anitbiotic resistant and necrotizing "flesh eating" since EPA
started promoting sludge biosolids as a fertilizer soil amendment in the 80s.

Bacteria reactivation / regrowth

Bacterial regrowth while airborne Bacterial division

Bacteria as known in 1986
Gerba's list of bacteria and parasites for landfill risk assessment, also see his list of viruses,

Bacteria listed by EPA in 1989

Lacking the support of its own scientists, the EPA sought approval from the general public. Public
perception of sludge, which was overwhelmingly negative, had to be overcome.

SACRAMENTO -- In a defeat for Los Angeles and Orange County sanitation agencies, a Senate committee
Tuesday narrowly endorsed a bill that would make it easier for Kern County to ban sewage sludge imports

Recent epidemiological studies have suggested that people affected by mental diseases show a high
prevalence for antibodies to certain viruses, such as Borna disease virus, herpes viruses and
endogenous retrovirus

One of the selling points in the EPA/WEF's promotion to farmers is their claim that the farmer and his
family will not be harmed by the use of sewage sludge and there will be no liability under the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (Superfund Act), if the
Part 503 is followed and sludge use is considered to be a normal application of fertilizer.

Please note that our group was the first to infiltrate the state's Biosolids Use Regulation Advisory
Committee (BURAC) and now has two (2) citizen representatives on the committee of waste industry
dominated representatives.

ANTIGENS AND ALLERGENS are a major concern for women and the elderly living near sludge disposal
sites and for people who are exposed by using sludge on their lawn and garden. Contaminated dust may
collect in their homes causing Organic Toxic Dust syndrome,

Biosolids - benign name for RCRA chemical and infectious solid hazardous waste disposed of as a

Birmingham Drainage District Index for court actions and documents - Kansas City, Misouri
         If you violate the laws long enough, courts, county and state will conspire to coverup.

Expert findings that cattle fed forage crops grown on sewage sludge had high to toxic levels of heavy
metals in tissue samples. [Document 33]

Symptoms commonly reported include respiratory infections, skin rashes, burning eyes, burning lungs,
difficulty breathing, and gastrointestinal effects. These effects can be more severe in
immunocompromised individuals, individuals with chronic disease, and other sensitive populations.
Similar health effects have been observed in workers at composting and sewage treatment facilities. In
some studies, workers have been shown to have higher rates of airway mucous membrane complaints,
respiratory inflammation, skin rashes, and diseases involving immunological hypersensitivity reactions

SACRAMENTO ;A measure by Senator Dean Florez, D-Shafter, to help end the dumping of Southern
California s treated human waste -- or sludge  on Kern County fields moved one step closer to approval
by the California State Assembly.

Virtually, every environmental law, and 503 ,states that if you are exposed to the organic chemicals (some
are metals), inorganic chemicals (metals) or pathogens through the air, food chain or water, their is a high
risk of death, disease or cancer. They also state the EPA Administrator has the documents on file to prove
the point.

The website has documented the EPA chemical and biological sludge war against
farmers and urban home owners since it began in 1978-79  to 2005 when politicians in California decided
to fight back

The question is did The Public Health Security and Bioterrorism Preparedness and Response Act of 2002
(Public Law 107-188; June 12, 2002) which requires that the United States improve its ability to prevent,
prepare for, and respond to acts of bioterrorism and other public health emergencies that could threaten
either public health and safety or American Agriculture, give the CDC any power to actually protect public
health and agriculture?

Morbidity and Mortality Weekly Report
Coccidioidomycosis — United States, 1991-1992
Valley fever epidemic

(33) The term pollutant or contaminant shall include, but not be limited to, any element, substance,
compound, or mixture, including disease-causing agents, which after release into the environment and
upon exposure, ingestion, inhalation, or assimilation into any organism, either directly from the
environment or indirectly by ingestion through food chains, will or may reasonably be anticipated to
cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions
(including malfunctions in reproduction) or physical deformations, in such organisms or their offspring;

USDA's Dr. Rufus Chaney, the last federal sludge salesman
Why does Chaney want to destroy our health, our farmland environment and put our neighbors at risk? Is
he a pathological liar with neurological damage or does he have criminal intentions?

Chemicals Organic and Inorganic


Chemical Regulations

EPA took Chromium out of the sludge rules under false pretenses. Using lime to Raise the sludge pH to 12
creates Chromium VI

A material is a hazardous waste under RCRA if it is a solid waste; as defined in 42 U.S.C.  6903(27) and is
hazardous as defined in 42 U.S.C. 6903(5). Both parties agree that the materials are hazardous; as that
word of art is used under RCRA, although (as we shall see) the EPA does not in fact regard them as
posing any material hazard if they comply with the conditions specified by the rule. The issue is whether
the materials in question are solid waste. The EPA has concluded that they are not-that so long as they
satisfy the stated conditions, they have not been discarded as RCRA's definition of solid waste uses the

Powerful diagnostic technology, plus the realization that organisms of otherwise unimpressive virulence
can produce slowly progressive chronic disease with a wide spectrum of clinical manifestations and
disease outcomes, has resulted in the discovery of new infectious agents and new concepts of infectious

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 becovered with soil in a landfill
within eight hours of leaving the treatment process that made it Class A.

Coliform -- a benign name for a group of deadly pathogenic bacteria EPA uses to determined if there fecal
pathogens in sewage effluents.

Coliform, Fecal  -- E. coli

Coliform fraud-- Where have all the Scientists gone?

Compost --sludge - biosolids index

Composted sludge for home use
Occurrence of Pathogens in Distribution and Marketing Municipal Sludges

Although the use of sludge as a soil amendment is attractive, it is not without potential health risks. Toxic
chemicals, including heavy metals and industrial organics, may enter the food chain and present long-
term health risks.

Compost Fact Sheet
EPA tells just how bad compost can endanger human health and the environment,

. EPA and the states' intent has been to get rid of upward of 10 million tons of very hazardous sludge with
the least possible paperwork and cost. Death, disease and cancer visited on the general public are simply
collateral damage. Governments are amoral and the collateral damage is just one of the cost of doing
business the public has to pay.

Buck says there is no single reason why the number of reported produce-related outbreaks in the U.S.
per year doubled between1973-1987 and 1988-1992 and why they continue to rise.

The foundation of our Country was based on common law and on the individual's right to life, liberty and
the pursuit of happiness. The founding fathers of our constitution ensured those individual rights in the

Congressional Bill H.R. 261 to label food grown on sludge. 2006
* U.S. Congressman Jose Serrano (D-NY) has introduced a bill since 1997.

Congressional Hearing on  EPA - 503
Congressional Public Relations stunt

Congressional Testimony - Jane Biswick
Threatened by Alan Rubin

Congressional Testimony.DavidLewis.html
These examples illustrate the almost unbelievable extent to which the EPA has corrupted the scientific
peer-review process in order to support certain political agendas and further the Agency's self-interests.




About 200 counties have banned the practice, Bob O'Dette, director of technical services of Synagro, told

The potential for pathogen regrowth is the downside to sewage sludge being rich innutrients that
promote the growth of bacteria and fungi.Exotoxins;& proteins and peptides secreted into the
surrounding environment by growing cells are produced by both gram-negative and gram-positive
bacteria. They are usually the most toxic of the two general types of bacterial toxins. Because they can
retain their toxicity at extremely high dilutions, some exotoxins, including staphylococcal enterotoxins
and shigatoxin, are used as biological warfare agents.

Traces of endotoxins in food and water can cause headaches, fever, fatigue, and severe gastrointestinal
symptoms; however, their primary target is the lungs. In addition to the former symptoms, inhaling
endotoxin-contaminated dusts can cause acute airflow obstruction, shock, and even death

It would appear that part 503 sludge rule violates the intent of the Act by turning our farms, homes and
gardens, school yards, golf courses and forests into nonpoint sources of pollution as well as creating
open dumps under the RCRA.