Obviously, EPA was forced to do something to discredit claims of injury from all over the country from sludge use. For
the purpose of debunking these horror stories, EPA appointed John Walker and Bob Bastian to work with WEF (Water
Environment Federation).

Hadeed reported that the wastewater industy has retained its number one status as the most dangerous career field
based on the results of the 1986 Annual WPCF Safety Survey.

David Lewis  on disinfection

by  JAMES W. BYNUM    DOT Qualified HazMat Transportation Trainer
GAIL M. BYNUM        Ph.D

SACRAMENTO -- There'll be no sludge deal after all. That was the word from state Sen. Dean Florez Monday, after
negotiations with Los Angeles officials broke down

Tonight, you can see for yourself what happens when sludge friends and foes-- three of them major figures nationally
-- are locked in a room for an hourwith cameras rolling.

In 1994 EPA put together a list of problem areas for sludge. EPA notified its partner, the Water Environment
Federation (WEF), of a writer it needed to hire and the stories he was to write about. EPA funded and ran the public
relations debunk the factual information.

Diseases (pandemic) in the United States 1980 - 2007

Disease Regulations

Disinfection injures bacteria and viruses

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 treatedeffluents and treated sludge in production of foodcrops, and no comparative
assessment is made of theeconomics of other use or disposal alternatives for sludge and wastewater.

Distribution and Marketing sludge/biosolids products
1988 EPA Study     Occurrence of Pathogens in Distribution and Marketing Municipal Sludges
         William A. Yanko,  County Sanitation Districts of Los Angeles County,

1988 EPA Study -- Trace Organics and lnorganics in Distribution and Marketing Municipal Sludges
Rodger Baird and Sylva M. Gabrielian,   County Sanitary Districts of Los Angeles County,

Direct exposure
"It's time we looked at direct exposure," Ruben said. "We have in the past concentrated on contaminates in the food

EPA chose the term Pollutant  to defined the chemical and infectious agents in part 503. While EPA and its scientists
do talk about pathogens, it doesn't seemed to be defined except by the Department of Transportartion. Most of the
infectious pathogens in sludge seem to be in the Risk 4 range.

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

It took physicians fifty years to accept Dr. Semmelweiss advise to wash their hands to prevent puerperal fever, so we
should not be surprised that it is only twenty years ago that engineers learned that EPA used a pollution test
incorrectly and as a consequence not only ignored a large portion of fecal waste in sewage, but all the pollution
caused by urine and protein waste.

However, according to the NRC report; A farmer considering the use of reclaimed wastewater or sludge will initially
have several concerns, including the potential health risks to family and employees, potential toxic effects on plants,
long-term detrimental changes in physical or chemical properties of the soil that may affect crop production, the
potential liability associated with the sale or consumption of crops grown using wastewater and sludges, and the fear
of liability for contamination of the land with hazardous waste.

Wastewater effluent is the cleanest treated water from a treatment plant which normally is returned to the rivers and
lakes and yet the NRC report found that it could contaminate the soil and ground water at a depth of almost 100 feet.

Vernon Alumbaugh, a toxic soils consultant out of Reno, Nev., said Thursday that he tested the soil at the Iniguez
home about two years ago and found high levels of endotoxins, which leads him to believe the family's home was built
on sludge. Endotoxins, which are released when bacteria is destroyed, have been known to cause severe
inflammation in any tissue exposed to them, including lung tissue, according to the national Centers for Disease
Control and Prevention

Congress found that due to the danger to human health land disposal of hazardous solid waste should be eliminated
as landfills and surface disposal polluted the land, air and water, and should be the least favored method of disposal.  
Congress found that the infectious characteristics of the pathogen pollutants in sludge makes it a hazardous waste

EPA spreads spore forming bacteria on lawns and school yards --
FDA Regulations

EPA Magic

EPA Compost can be dangerous

EPA's Alan Rubin keeps insisting that there is nothing hazardous about sewage sludge, especially as it pertains to
shipping it from a point source of pollution to the farm where it becomes a non-point source of pollution. Due to the
infectious nature of sludge it is a hazardous substance under the RCRA and a pollutant under the CWA, which makes
it a hazardous material under the DOT regulations.

For example, wastewater treatment sludge from thechemical conversion coating of aluminum is a listed hazardous
waste in the RCRA regulations.  If this waste is sent to a POTW via a sewer where the waste mixes with domestic
sewageprior to reaching the POTW's treatment plant, then the wastewould be covered by the domestic sewage
exemption, andtherefore would not subject the POTW to a RCRA permit. If,however, the same waste is trucked
directly to the POTW, then the waste would still be considered hazardous waste  and the POTW would be required to
have a RCRA permit to accept such waste.

DOCUMENTED CASE OF HARM FROM SLUDGE.Yet, EPA seems to have put pressure on the WEF to front the
campaign. EPA's John Waker and Bob Bastian put the program together.

Over the past 15 years, farms have been destroyed as a result of EPA's promoting hazardous sewage sludge as a
safe fertilizer. Lives have been destroyed as a result of EPA's promoting hazardous sewage sludge as a safe fertilizer.
Deaths have occurred. Over the past thirteen years, numerous organizations across the country have been organized
to stop or ban the disposal of hazardous sewage sludge.

EPA Sludge Manual Update
"We're looking at a document that is 26 years old," said James Smith, a senior environmental engineer who is
heading up the project. Smith also is chair of EPA' Pathogen Equivalency Committee. With all of the information that
has been published since the first manual was printed, " is impossible to find a body of knowledge in one place," he

In 1993, under court order, EPA's Office of Water released a deadly sewage sludge disposal program it likes to refer
to as a regulation. The main purpose of the program was to be able to issue removal credits to polluters for land
application of ten toxic and very hazardous inorganic chemicals. EPA had no concern for what the military would call
collateral damage of sludge disposal (i.e., death, disease, cancer).

The problem is that after causing untold amounts of human health and environmental damage, the regulators look like
fools and criminals. This was not unexpected by one man who wrote, if Congress gives EPA regulatory authority over
hazardous wastes? Will we have one policy for hazardous wastes which go through municipal treatment plants and a
different policy if it goes through and industrial treatment plant? if so, we will end up in court looking like fools.

The CWA definitions are biased toward protecting organisms in, on, or near water. Humans and animals fall into that
organism category. Under the CWA sewage and sludge is a pollutant. Under the sludge regulation pollutants are
everything in sludge that will kill us -- and -- none were addressed in the regulation as a risk to human life.

EPA Exposure pathways for pathogens in sludge/biosolids/
2003 revision of 1992 document

At no time during this period was he instructed as to the proper handling of sludge, safety precautions to be followed,
or the hazards or increased risks associated with exposure to sewage sludge,   He was taken the emergency room
April 8, 2001, with chest and arm pain, shortness of breath, and a feeling that he was choking on mucus. In February
2002, he underwent a sternotomy so that cultures could be taken from his lungs. During the procedure, Michael Seth
Jones' thymus, as well as a large mediastinal mass, were removed.The lung biopsies, according to the complaint,
found several abnormalities, including Enterococcus Faecalis in his left lung and Nocardia in his right lung.
Enterococcus Faecalis is a ;rare gram-positive streptococcus (bacteria) species found in sewage sludge

FECAL COLIFORM in sewage sludge biosolids and reclaimed water

It appears, as already noted, that in the NRC Report, no one took into consideration the federal laws
concerningsewage sludge which are very precise -- sludge from any pollution control plant is classified as a solid
waste which must be disposed of in a sanitary landfill without exception. If it is disposed of in any other way it
isconsidered an open dump. These laws give precise definitions:

I was notified by several Brunswick citizens that there is a proposal before the town council to allow the spreading of
sludge over groundwater supplies. I hope and pray that the town council will use wisdom and consider its public duty
in safeguarding the water supply of the people they represent. The residents of Brunswick deserve nothing less.

Standards for 126 contaminants considered priority pollutants  would be aggressively tested for and strictly enforced
under SB 120. Florez doubts many plants are currently meeting these standards, including those which would supply
the proposed Synagro plant.

Flow chart

Food labeling Bill for food grown on sludge

Food Poisoning from hazardous substances in sludge biosolids, reclaimed and drinking water

Fungus  (index) in sludge biosolids and compost

Gatekeepers - Sludge biosolids spokespeople with little or no knowledge

As the highly educated Director of the Georgia Environmental Protection Division,we would like to believe you are
aware of the definition of a hazardous substance in the RCRA, a toxic pollutant in the CWA and a polluant in 40 CFR
503.9(t) which shows that exposure to Sludge/Biosolids meets the definition of exposure to a biological weapon. This
could cause death, disease, cancer as well as physical and mental disorders.

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.

1986, Development of a Qualitative Pathogen Risk Assessment Methodology for Municipal Sludge
Landfilling  also see
Streptococcus and Staphylococcus
Staphylococcus survival


With Holmstrom's guidance in the process, students obtained evidence of not only pressure from
polluters on CU s administration to undermine my job in apparent retaliation for my research and public
disclosures on significant environmental health and safety threats in the state, but also high level
meddling by officials of Colorado's right wing Governor Bill Owens who, records show, has been
inadequately enforcing Colorado's environmental laws and doing sweetheart deals with polluters.CU
officials and Environmental Studies Director Jim White had attempted to deny there was any such outside
political or corporate pressure.

The Health, Education, and Social Services (HESS) Committee along with other members of the 2004-2005
Kern County Grand Jury, pursuant to Penal Code Section 925 has for the past five months investigated
the use of Biosolids  on land in Kern County. The investigation was initiated by the published concerns of
many stakeholders regarding the close proximity of biosolid use over the Kern Water Bank and local
aquifers. The source of the biosolids is also of concern to residents.

EPA's original research on sludge composting was done by Los Angeles County Sanitation Department.
That research showed that EPA's standard test procedures didn't find all of the pathogens in Class A
compost. The study showed in 1987 that marketed compost had the potential to be very deadly to public

There are 73 groups in 21 states and the District of Columbia which have expressed their concerns over
the use of Hazardous sewage sludge as a fertilizer.If your group is not on this list and you wish to express
you concern, please notify us
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