Sewage sludge (Biosolids) is a potential killer

National Sludge Alliance
Fact Sheet # 138

Sewage sludge (Biosolids) is a potential killer.

The governments of Australia, Canada and the Congress of the United States of America have
recognized that death and injury will result from exposure to chemicals and disease causing
micro-organisms in sludge.   Therefore the question is, why is Congress funding the National
Biosolids Partnership's (Environmental Protection Agency (EPA) and Water Environment
Federation (WEF)) public relations “debunking” campaign to deny that there are victims of
sludge land spreading and convince the public that sludge used as a fertilizer is safe?

The Biosolids Partnership appears to misrepresent the true danger of treated sludge to WEF
members as well as the public. As an example, the Miami-Dade Water and Sewer Department
recently misrepresented the quality of treatment possible when it  published the statement:
"Stabilized biosolids have no odor and are free of disease-causing organisms." (9)

The fact is that there can be no scientific study which  shows sludge is free of disease causing
micro-organisms  or that it is safe to use as a fertilizer on lawns and food crops.The National
Academy of Science 's (NAS) recent Committee report on toxicants, states that it is impossible
to do a risk assessment to prove sludge use under part 503 is safe. The scientific statement is
very blunt: FINDINGS,"-----the remaining uncertainty for complex mixtures of chemical and
biological agents is sufficient to preclude the development of  risk-management procedures
that can reliability result in acceptable levels of risk." (4)

As an example, in Australia, the Veterans' Entitlements Act of 1986 includes both Class A and
Class B type sludges as a cause of injury, disease or death under the International
Classification of Diseases (ICD),Code 495, for extrinsic allergic alveolitis. A formal statement
says, "The Repatriation Medical Authority is of the view that there is sound medical-scientific
evidence that indicates that extrinsic allergic alveolitis and death from extrinsic allergic
alveolitis can be related to relevant service rendered by veterans, members of Peacekeeping
Forces, or members of the Forces."

What do Australia authorities think is capable of inducing an immune response and reacting
with the specific antibody or specifically sensitized T-lymphocytes to produce a response that
could cause your body to kill itself? The Repatriation Medical Authority says, "The major
categories of antigens causing extrinsic allergic alveolitis are microbial agents, animal proteins
and low molecular weight chemicals (haptens)."

"According to the Authority, "Examples of antigen containing material include: "Sewage sludge
contaminated with micro-organisms, Fertilizer contaminated with micro-organisms, Compost
dust contaminated with micro-organisms"".  (4)

The Canadian government explains the nature and symptoms of the ICD Code 495 group of
lung diseases under its rules. The Canadian Centre for Occupational Health and Safety lists
"Sewage sludge disease" as a major concern. It is caused by dust of heat-treated sludge. That
would be our "safest" Class A sludge fertilizer "Milorganite" which has been sold by the City of
Milwaukee since 1926. Sewage sludge disease is one of a group of lung diseases resulting
from exposure to dusts of animal and vegetable origin. This group of diseases is called
extrinsic allergic alveolitis. According to the Centre, "The name, although complicated,
describes the origin and the nature of these diseases:
"extrinsic"-- cause originating outside the body
"allergic"-- caused by the allergic reaction of the body to a specific substance or condition
"alveolitis"-- an inflammation in the inner part of the lungs (alveoli - small air sacs in the lungs)"

The Centre says, "once a person is sensitized, [they] can show three different types of    
responses: acute (intense) response, sub-acute (recurrent) response, and chronic (long-term)

The acute attack is triggered by heavy exposure to dust. It starts with fever, muscular aches
and a general, unwell feeling or malaise. These symptoms are accompanied by tightness in
the chest, a dry cough, and shortness of breath.

The sub-acute response occurs most frequently to people exposed to relatively low levels of
dust. It is marked by cough, shortness of breath, sweating, sore throat, headache, and nausea.

The chronic response develops after persistent acute attacks and recurrent sub-acute
responses. Responses are marked by increasing shortness of breath, occasional fever; loss of
weight, and general lack of energy. The victim suffers permanent lung damage and, in the
worst cases, death may occur. " (2)

I think we can now understand why EPA pulled the plug early on the infamous 1985 "Ohio
Health Study".  According to EPA and WEF sludge experts the Ohio Health Study proved
sludge is safe to use as a fertilizer on lawns and food crops. However, the field research was
never completed. It would appear that none of these experts have ever read the complete
study, because (Dorn, 1985) actually said, "Caution should be exercised in using these data to
predict health risks associated with sludges containing higher levels of disease agents and
with higher sludge application rates and larger acreages treated per farm than used in this

Yet, the EPA/WEF partnership used this study to justify promoting disease causing micro-
organisms contaminated sludge on pastureland as a fertilizer. The National Sludge Alliance
read the study, rather than the abstract, in 1997 and found that Dorn referred to the World
Health Organization (WHO, 1981) study which "reported a positive association and a cycle of
infections of Salmonella from humans to sludge to animals to humans where cattle grazed on
sludge treated pastures. (Municipal Sewage Sludge Application on Ohio Farms: Health Effects.
Dorn, R.C., et al, Environmental Research 38, 332- 335)" (NSA # 109)

In the United States, environmental agencies have more statutory power than the public health
agencies. Therefore, medical professionals do not investigate or speak about sludge related
diseases unless invited or approved by environmental agencies. As an example, the National
Institute for Occupational Safety and Health (NIOSH)  refers to ICD Code 495 diseases as
"organic dust toxic syndrome", rather than extrinsic allergic alveolitis.

In 1994, (NIOSH warned that 3.4 million, "Agricultural workers are at risk for developing
respiratory illness from exposure to inhaled dusts. One of the most common illnesses is
[organic dust toxic syndrome] ODTS, a respiratory and systemic illness that may follow
exposures to heavy concentrations of organic dusts contaminated with microorganisms [do
Pico 1986; Parker et al. 1992]. An estimated 30% to 40% of workers exposed to organic dusts
will develop the disease [do Pico 1986; Rask-Andersen 1989]."

NIOSH states, "ODTS typically occurs where a large amount of organic dust is present in the
air. The syndrome often occurs in small clusters and affects most individuals who are exposed
to heavy concentrations of organic dust contaminated with microorganisms [Brinton et al.
1987]. ODTS appears to result from inhaling particles and toxins produced by microorganisms
such as gram negative bacteria (Pseudomonas species, Enterobacter agglomerans, and
Klebsiella species), thermophilic organisms (Aspergillus fumigatus and Micropolyspora faeni),
and fungi [Schenker et al. 1991]. Endotoxin1 is a common component of organic dust in
agriculture [Olenchock et al. 1990; Dutkiewicz 1987] and may be involved in the development
of ODTS. (7)

In July 2002, NIOSH published its, "Guidance For Controlling Potential Risks To Workers
Exposed to Class B Biosolids" There was a major disclaimer: "This guidance is not intended to
address nonoccupational exposure". In fact, it doesn't address farmers or home owner

NIOSH Guidance manages to alert the public to some of the danger signals in the document
even though it downplays the potential for death. It says: "EPA estimates that 7.1 million tons
of biosolids were generated for use or disposal in 2000."

Furthermore, "The disease risk is a function of the number and types of pathogens in the
Class B biosolids relative to the exposure levels and infective dose. Because data are sparse
on what constitutes an infective dose, it is prudent public health practice to minimize workers'
contact with Class B biosolids and soil or dusts containing Class B biosolids during production
and application, and at land application sites during the period when public access is
restricted. Class A biosolids may also present some health risk to workers, since some
chemicals and biologic constituents in Class A biosolids are not regulated by the EPA."

NIOSH makes a point to warn against exposure to "soil or dusts containing Class B biosolids"
rather than exposure to "organic dusts contaminated with microorganisms". Not only that, but
NIOSH fails to mention the possibility of"respiratory and systemic illness". Instead, NIOSH
states, "Exposure may potentially result in disease (e.g., gastroenteritis) or in a carrier state in
which an infection does not clinically manifest itself in the individual but can be spread to
others. These enteric organisms are usually associated with self-limited gastrointestinal illness
but can develop into more serious diseases in sensitive populations such as immune-
compromised individuals, infants, young children, and especially the elderly."

As for health protection, NIOSH says, "EPA does recognize that occupational exposure can
occur and states that workers exposed to Class B biosolids might benefit from several
additional precautions such as use of dust masks when spreading dry materials, the use of
gloves when touching biosolids, and routine hand washing before eating, drinking, smoking, or
using the bathroom." (8)

NIOSH couldn't even publish the true facts as EPA had related them to Congress: "(13) The
term "toxic pollutant" means those pollutants [sewage, sludge, solid waste, radioactive material,
etc], or combinations of pollutants, including disease causing agents, which after discharge
and upon exposure, ingestion, inhalation or assimilation into any organism [living entity], either
directly from the environment or indirectly by ingestion through food chains, will, on the basis
of information available to the Administrator, cause death, disease, behavioral abnormalities,
cancer, genetic mutations, physiological malfunctions (including malfunctions in reproductions)
of physical deformations, in organisms [humans and animals as well as microorganisms] or
their offspring." (Title 33, part 1362)

There have been studies proving Congress was right. In a 1998 published neurological of
study, Dr. Raymond Singer found that, "This complex substance poses a significant neurotoxic
threat to farmers, their workers, nearby residents, and possibly to the general population
through the food supply."

Singer's conclusion was that, "Municipal sewage sludge poses a measurable neurotoxic hazard
to nearby residents and farm workers, who need to be informed of possible neurotoxic injury
from their exposure, and then monitored using repeated neurobehavioral tests." (6)

In the United States, and other countries where the WEF helped to promote sludge use, the
Environmental Protection Agency (EPA) contends there are no documented cases of harm to
human health from the use of sludge. However, that is because EPA prefers to think of
humans not protected by the federal Occupational Safety and Health Administration (OSHA)
rules under the scientific term of "organisms".  However, EPA fired Microbiologist, David Lewis
for questioning the use of sludge as a fertilizer. Fortunately for the country, Dr. David Lewis
published a study of sludge victims verifying a ICD Code 495 connection.   

Lewis found, "The primary complaints (a fourth or more reporting the symptom) within 1 h of
exposure were coughing (63%, 8 sites), burning throat (56%, 10 sites), burning eyes (56%, 9
sites), and headaches (46%, 6 sites). Within 24 h, residents developed nasal and chest
congestion (77%, 7 sites), difficulty in breathing (71%, 8 sites), nausea/vomiting (46%, 7 sites),
fatigue (33%, 7 sites), and flu-like symptoms (29%, 5 sites). In some cases, symptoms of
chemical irritation (e.g., burning eyes, burning throat) recurred for over a year after
applications ceased."

Lewis also found, "Two cases involving mortality from S. aureus occurred with individuals who
directly contacted freshly applied biosolids. In the first case, an 11-year-old male in Osceola
Mills, PA with an unremarkable medical history died of staphylococcal septicemia. The patient
developed a sore throat, headaches, and furuncles on one leg and one arm within several
days after riding a motorbike through sewage sludges applied nearby for mine reclamation
purposes. A primary care physician prescribed antibiotics and the patient was admitted to the
hospital the following day with difficulty in breathing and high fever."  Within days, this child was

Lewis' most disturbing find was, "Overall, 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." (10)   

According to Senate and Congressional documents, as well as these documents, the odds are
that if you or your family have suffered a death, cancer or severe illness of any type (brain,
heart, lungs or immune system) they were at some point exposed to environmental pollutants
(chemicals and/or deadly disease causing organisms) either by direct environmental contact or
indirectly through air, water or food. Federal, State and City health departments have failed to
investigate health complaints associated with sewage sludge disposed of as a fertilizer
because their hands are tied.   The environmental protection departments must give their
permission for any medical investigation.

Therefore, the National Sludge Alliance has always advocated a total ban on the use of
sewage effluent or sewage sludge in any form that could expose animals, humans or the
environment to toxic sludge pollutants. (1) --LSI--

1. RCRA and CWA

2. Canadian Centre for Occupational, Health and Safety http://www.ccohs.
3. Australia, Instrument No.57 of 1997, Determination of Statement of Principles
Veterans' Entitlements Act 1986
4. Biosolids Applied to Land: Advance Standards and Practices, Committee on Toxicants and
Pathogens in Biosolids Applied to Land, National Research Council, National Academy of
Science's, National Academy Press, Washington, 2002
5. Dorn CR, Reddy CS, Lamphere DN, Gaeuman JV, Lanese R. , Municipal sewage sludge
application on Ohio farms: health effects, Environ Res 1985 Dec;38(2):332-59

6 Singer, R. (1999). Neurotoxicity from municipal sewage sludge. Archives of Clinical
Neuropsychology,14, 160; Singer, R. (1998). Neurotoxicity from municipal sewage sludge.
Presented at the 18th Annual Meeting of the National Academy of Neuropsychology,
Washington, D.C., November 6, 1998.
7. NIOSH Publication No. 94-102, April 1994, Request for Assistance in Preventing Organic
Dust Toxic Syndrome,
8. DHHS (NIOSH) Publication Number 2002-149,Guidance For Controlling Potential Risks To
Workers Exposed to Class B Biosolids
9. Miami-Dade Waste and Sewer Department, About Wastewater Treatment, copy write 2003,
Channing Bete Company, South Deerborn, MA.
10. David L Lewis1, 2 , David K Gattie3 , Marc E Novak2 , Susan Sanchez4 and Charles  
Pumphrey5 Interactions of pathogens and irritant chemicals in land-applied sewage sludges
(biosolids)1US Environmental Protection Agency, National Exposure Research Laboratory,
Athens, GA, USA2Departments of Marine Sciences University of Georgia, Athens, GA, USA
3Biological & Agricultural Engineering University of Georgia, Athens, GA, USA
4Medical Microbiology University of Georgia, Athens, GA, USA
5Prime Care of Sun City, Menifee, CA
BMC Public Health 2002 2:11. Http://