Chapter One
INTRODUCTION
The 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", dealt with the public health
perception issues associated with the toxic sludge used
in the production of crops for human consumption.
The public perception issues included: (1)
transmission of infectious diseases from the use of
sludge on food crops, (2) scientific evidence to prove
sludge was safe for use on food crops, (3) government
regulations to protect the public health from the use of
untreated sewage sludge or mishandling of sewage sludge
on food crops.
According to the report, the NAS was chartered in
1863, as a private, nonprofit society of distinguished
scholars engaged in scientific and engineering research
for the general welfare of the public, and with a
mandate that required it to advise the federal
government on scientific and technical matters.
Although the National Research Council (NRC), the
principal operating agency of NAS, is given credit for
writing the report on public health perception, the
report indicates it was reviewed by an internal
committee from the NAS, and its other operating
agencies, the National Academy of Engineering, and the
Institute of Medicine. Therefore, the total
responsibility for this report, which advised the
federal government (Congress) that sludge used on crops
is safe belongs to the NAS.
The NAS Committee based their premise that sludge
was safe for use on crops on the assumption that: (1)
the EPA's risk assessment was accurate, (2) the federal
regulations were the laws, (3) the regulated procedures
would be followed to the letter, (4) the treatment
process and equipment would consistently produce the
same quality of sludge, (5) there were no scientifically
documented outbreaks of infectious diseases from the use
of sludge on crops.
According to the report, the rationale for the
literary review was the EPA's concern with the "food
processing industry's reluctance to accept the practice"
(of using sludge on crops grown for human consumption),
which was promoted by the (Environmental Protection
Agency) EPA, the (Food and Drug Administration) FDA, and
(United States Department of Agricultural) USDA, first
with a federal policy statement in 1981 on the use of
sludge for fruits and vegetables (EPA Report No.
SW905), and then as the published official EPA
beneficial sludge use policy (WH-595) in 1984, and now
as the 1993 sludge use regulation (guideline) 40 CFR
503, which the report refers to as the law.
The apparent purpose of the report is stated by the
NRC's Water Science and Technology Board (WSTB) "formed
a committee representing diverse expertise and
perspectives to conduct an independent study of the
safety and practicality of the use of these materials
(sludge) for the production of crops for human
consumption."
However, the NRC acknowledges in the Preface of the
report that this is a very biased report, funded by the
federal agencies and sludge dumpers in an effort to
change public health perceptions. It is directed at the
food processors, because the food processing industry
has been concerned about the safety of crops grown on
sludge, since the EPA, FDA, and USDA first "-developed a
joint statement of federal policy in 1981 to assure that
current high standards of food quality would not be
compromised by the use of high quality sludges and
(im)proper management practices." Apparently, according
to recent media articles, some food processors have now
been convinced that sludge is safe for use on crops.
In reality, there was no high quality sludge in
1981, nor are there any high quality sludges today, as
indicated by EPA research in the preamble to the sludge
use and disposal regulations. The preamble to the part
503 regulation outlines the EPA's own literary review,
assumptions, lack of research, and warns that sludge is
not safe. In fact, the information given in the preamble
to part 503 as well as the regulation itself discredits
the NRC report and the Committee for its lack of basic
research methodology in the literature review. The
EPA's cleanest sludge is too contaminated with toxic and
hazardous substances to be placed in a part 503
regulated landfill.
Furthermore, the NRC Committee were aware that the
EPA, FDA and USDA approved the use of sludge on crops
when, according to the EPA, "Methodologies and data are
not yet available to accurately estimate the ecological
impacts from the use and disposal of Sludge" (FR 54-p.
5780). Data on processed sewage sludge was generally
not available from the special "40" city study (a
survey) to determine the fate of priority toxic
pollutants entering the treatment plants. Moreover, at
the time of the study in 1979 and 1980, analytical
methods for measuring organic pollutant concentrations
in materials with high suspended contents were in their
infancy (FR 54-p.5763). not only that, but in the final
form (proposed regulation) numerical limits were
proposed for only 28 pollutants. Dioxin was not
included as a pollutant in this list because the EPA
lacked adequate data on the levels or pervasiveness of
it in sludge. Nor did the EPA have adequate test
methods to determine the amount of dioxin in sewage
sludge (FR 54-p. 5760).
Furthermore, according to the EPA, on farmland, "no
accounting is made for removal by (1) soil erosion, (2)
leaching, (3) volatilization, or (4) absorption of the
plant and removal of the harvested portion of the plant"
FR 54-p.5768-5770).
The NRC report does note that higher levels of some
of the 126 priority toxic pollutants in sludge could be
placed on the land than allowed by part 503: "...and may
undermine the intent of the Part 503 Sludge Rule and
public confidence in the law." (p. 138) A pollutant can,
according to the EPA, damage health, cause deformation
of fetuses or cause death.
Furthermore, the NRC Committee states, "The (public
perception) study did not include an investigation of
what happens after the crops are harvested (e.g.,
processing of food products). (p. viii)
It is highly unusual that a scientific body would
attempt to influence the food industry, by concluding
that sludge was safe for use on food crops, without a
complete investigation of the pollutants in crops grown
on sludge amended soils.
Prev Next
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"
Back
By 2002 the National Academy of Science knew it
had been improperly used by EPA and tried to
protect it's reputation with a new study claiming
EPA needed to update its science, because there
had been no literature review, (they did not
even review Part 503.9(t)), some of the original
researchers for part 503 had run the part 503 Peer
Review Committee and moved on up to run the
NRC Committee -- knowing there had never been a
cancer risk assessment for chemicals, metals or
pathogens. Two key researchers and members of
both committees are listed below the 2002 Press
Release.
The new study was chaired by Thomas A. Burke,
professor, department of health policy and
management, Johns Hopkins University Bloomberg
School of Public Health, a colleague of the
co-author of this 1996 report, Michael Baram, a
professor of public health law at the Boston
University School of Public Health, one of the 14
authors of the report, who disagreed with the
reports conclusion, not for the misstatements of
facts on the federal regulations or law, but for the
infectious disease aspects.
2002 -- National Academy of Science
Committee on Toxicants and Pathogens in
Biosolids Applied to Land
Press Release
FOR IMMEDIATE RELEASE
Sewage Sludge Standards Need New
Scientific Basis
WASHINGTON -- The U.S. Environmental
Protection Agency's standards that govern using
treated sewage sludge on soil are based on
outdated science, says a new report from the
National Academies' National Research Council.
The agency should update its standards using
improved methods for assessing health risks, and
should further study whether treated sewage
sludge causes health problems for workers who
apply it to land and for residents who live nearby,
added the committee that wrote the report. More
rigorous enforcement of the standards is needed
as well.
"There is a serious lack of health-related
information about populations exposed to treated
sewage sludge," said committee chair Thomas A.
Burke, professor, department of health policy and
management, Johns Hopkins University Bloomberg
School of Public Health, Baltimore. "To ensure
public health protection, EPA should investigate
allegations of adverse health effects and update
the science behind its chemical and pathogen
standards."
More on the press release
Two very Biased experts
Albert Page, University of California, Riverside,
Committee Chair states, "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."
http://deadlydeceit.com/NAS-Review.html
Dr. Al Page of the University of California at
Riverside (UCR), who was co-chair of the [part 503]
Peer Review Committee with Dr. Logan was listed
as a metal bioavailability expert, as was
Dr. Andrew Chang, Page's colleague at UCR, was
another metals bioavailability expert.
http://www.deadlydeceit.com/peer-review.html
NRC - Use of Reclaimed Water and Sludge in
Food Crop Production
Albert L. Page (Chair) is Professor of Soil Science
and Chemistry and Chair of the Department of Soil
and Environmental Sciences at the University of
California at Riverside. Dr. Page received his B.A.
in chemistry from the University of California at
Riverside and his Ph.D. in soil science from the
University of California at Davis. his current
research interest is on the fate of trace elements
when applied to soils in the form of environmental
wastes.
Dr. Page was a member of the National Research
Council's Committee on Irrigation Induced Water
Quality Problems.
Andrew C. Chang is Professor in the Department
of Soil and Environmental Sciences, and Director of
the Kearney Foundation for Soil Science at the
University of California, Riverside, California. He
received his Ph.D in Agricultural Engineering from
Purdue University. His areas of research include
the land application of municipal wastes,
environmental chemistry of phosphorus, physics
and chemistry of organic pollutants, and
methodology of establishing land disposal criteria.
He [and Al Page] has conducted a study for the
World Health Organization on Human
Health-Related Chemical Standards for using
Reclaimed Wastewater for Crop Irrigation and
Sewage Sludges for Fertilizer. He has served
on several state and federal committees for risk
assessment of municipal sludge disposal.
Dr. Chang received the 1991 U.S. Environmental
Protection Agency Sludge Beneficial Use Award for
research, and the 1991 U.S. Department of
Agriculture Superior Service Award for Natural
Resource and Environment.
http://books.nap.edu/openbook.php?record_id=517
5&page=175