Toxic Organic sludge Dust is Not Good for You

                                            Deaths doubled in 15 years --1980/1995
National Sludge Alliance
Fact Sheet # 139

Toxic Organic sludge Dust is  Not Good for You
Deaths doubled in 15 years --1980/1995

The year 1993 was not a good year for science, the law or public health. It was especially bad
for farmers and the general public who depend on science and the law for protection from
pollution. In 1993 the Water Environment Federation (WEF) documented  that  toxic organic
sludge dust is a fire and explosive hazard very similar to grain dust.  Organic dust will carry
chemicals and disease causing germs, yet, EPA released its blanket dumping permit for use of
toxic sludge as a fertilizer as a federal regulation .  In addition, the Supreme Court's 1993
ruling in the Daubert vs. Merrell-Dow case now makes it vertually impossible to get a toxic
health damage claim against a polluter into court based on expert scientific witnesses. Daubert
lost and that has become the rule for judges. The scientific problem judges face is illustrated in
a New York Times article. "For example, a 1994 E.P.A. brochure says that biosolids may
"protect child health." The brochure cites a study showing that animals that ingest
"biosolid-treated soil and dust may have a decreased absorption of lead into the blood stream,
thus lessening the potential for lead-induced nerve and brain damage."(13)  Legal experts are
now recognizing the damage. "The result is that the jury trial process is being subverted and
there are signs the influence of Daubert is impacting the regulatory arena, Michaels told
reporters at a press briefing in Washington, D.C."(12)  Few experts realize EPA based its 1994
sludge PR promotion and victim debunking campaign on the manipulation of science and the
law.  Some experts still believe only private interests would stoop that low. "Private interests
have latched onto the ruling and are using it "to manipulate and abuse science," said Dr.
David Michaels, a research professor of environmental and occupational health at George
Washington University. "(12)

The basic principle behind the 503 blanket sludge dumping permit was that EPA claimed it had
insuficient data on most chemicals and disease causing germs to regulate them in sludge. EPA
almost won on this issue when all of its sludge scientists and the first National Academy of
Science Committee looking at EPA rules gave sludge a clean bill of health. EPA placed the
burden of proof for producing good science on the sludge victims who may not be aware that
the air, water and food can all carry the organic dust loaded with toxic chemicals and disease
germs offsite. That became a nightmare for neighbors of one Pennsylvania sludge disposal
site. According to the Toxic Law Reporter, "The Pennocks' son Daniel contracted a rotavirus
and staph infection in March 1995 that attacked his lungs and led to his death just two weeks
later". (14)  Daniel may be only one of 100,000 deaths attributed to toxic organic dust
syndrome. Yet, "The Daubert ruling has allowed lawyers and judges to demand certainty from
science that is not in line with what the law would require, Berger explained. It is in particularly
troubling for toxic tort cases, Berger added, where a plaintiff relies on scientific experts to
demonstrate causality. With so much unknown about the toxicity of the vast array of chemicals
individuals can be exposed to, it is very rare for scientists to reach definitive conclusions.
Critics say the Daubert ruling allows defendants to exploit this uncertainty and to toss out the
scientific evidence and experts that are the foundation of many toxic tort cases."(12)

The EPA's favorite sludge experts say there are no pollutants in sludge. In Chapter 8 of the
1995 book Toxic Sludge is Good for You! -- Lies Damn Lies and the Public Relations Industry
John Stauber and Sheldon Rampton give the ultimate example of a "damn lie" fostered by
EPA, "A few months after the debut of "biosolids," the Water Pollution Control Federation
dropped the words "pollution control" from its own name and replaced them with "environment."
At the group's 64th annual conference [1991], WEF President Roger Dolan explained the
reasoning behind the latest name change: "We don't control pollution anymore; we eliminate
it."" (3)

That would work in court if the victim did not know that the Water Pollution Control Federation
documented in 1986 that sludge borne bacteria and viruses could survive in soil for up to a
year. It also documented that bacteria could survive on plants for up to six months. (8).
Furthermore, the new and improved Water Environment Federation (WEF) documented in
1993 that organic sludge dust , which carries chemicals and disease germs, is very similar to
grain dust, which is a fire and explosive hazard.  (11)

The National Sludge Alliance (NSA) Fact Sheets have documented how the EPA/WEF
partnership eliminated pollution for public wastewater works, by creating the part 503 permit
and dumping sludge on farmers and unsuspecting homeowners who bought sludge as a
fertilizer. NSA also documented the WEF managed sludge victims debunking program, funded
by EPA and supervised by EPA's John Walker and Robert Bastian. NSA has also documented
the astronomical increase in annual food poisoning incidents between 1990 (6 million) and
1997 (80 million). Various government estimates have indicated annual deaths from food
poisoning at 5 to 9,000. However, it now appears that those numbers are only the tip of the
iceberg when we look at health effects and deaths related to toxic organic dust. (4)

To understand how we got here, we need to look at EPA's PR spin on the original sludge use
program that focused on the imagined effects of odor. According to Stauber and Rampton,
"The EPA's PR strategy for sludge was first outlined in a 40-page report published in 1981 with
a classic bureaucratic title: "Institutional Constraints and Public Acceptance Barriers to
Utilization of Municipal Wastewater and Sludge for Land Reclamation and Biomass Production"
(imagine the acronym: ICPABUMWSLRBP). It warns that there is an "irrational component" to
the public's attitude toward sludge, including the widely-held notion that sludge smells bad: "It
is difficult to say to what extent odors emanating from sludge may be imagined. However, it is
the most common ground voiced by opponents in taking action against land application
projects." In addition, "the growing awareness about hazardous wastes and the inadequacy of
their past disposal practices will inevitably increase public skepticism."" (3)

Sludge experts love to say  toxic sludge is not a hazardous waste. However, the term
hazardous waste has no direct meaning in relationship to human health effects. EPA defined a
hazardous waste in FR, 43, #243, p. 58953 to include those pollutants that will leach out of the
soil into groundwater at levels 10 times higher than those allowed in the drinking water

NSA documented in Fact Sheet # 138 that exposure to toxic dust in Class A heat dried sludge,
compost, as well as contaminated fertilizer will cause lung diseases. It is no stretch of the
imagination to tie exposure to toxic sludge dust and the health effects together. NSA has also
documented that federal agencies can not address the issues because they signed off on
EPA's National Sludge Disposal Policy.  But all is not lost, OSHA implied it thought
sludge/Biosolids was only used as a fuel when it said, "The National Fire Protection
Association (NFPA) forwarded to the Occupational Safety and Health Administration (OSHA) a
research paper (1) which reported on potential hazards involved with processing, conveying
and storing of dried biosolids derived fuel (BDF). BDF is used in a number of industrial
applications.  The paper indicated that organic dust can be generated during the storage of
BDF. It also asserted that another organic dust similar to biosolids dust was grain dust." (11)

By 1994, the Swedish National Board of Occupational Safety and Health (SNBOSH) on Organic
Dust in Agriculture recognized the danger of toxic dust in agricultural. They say, "Health
problems affecting the respiratory organs of persons employed in agriculture are to a great
extent work-related; that is, the causes of illness are to be found at the workplace. Persons
employed in agriculture have a higher lung disease mortality rate than the population
generally, despite fewer of them being smokers. Exposure to organic dust can also give rise to
chronic bronchial catarrh, coughs, nasal catarrh and nasal congestion." (7)

SNBOSH also says, "Acute toxic alveolitis, otherwise known as "organic dust toxic syndrome"
(ODTS), can accompany brief, occasional exposures to heavy concentrations of organic dust
in agricultural environment. The contents of the dust inhaled can include fungal spores,
bacteria, bacteria spores and endotoxins. Symptoms of illness often become apparent
between 4 and 8 hours after inhalation of heavily concentrated organic dust". (7)

About the same time, the National Institute of Occupational Safety and Health (NIOSH)
recognized that the United States had a similar problem. According to the NIOSH, "Chronic
Obstructive Pulmonary Disease "(COPD) has become a major public health concern. In 1995,
it ranked as the fourth leading cause of death in the United States, accounting for over
100,000 deaths--nearly twice as many as in 1980 [NCHS 1997]. In 1994, an estimated 16
million individuals in the United States had the diagnosis of COPD, representing a 60 percent
increase since 1982 [ALA 1996]." (1)

According to the NIOSH, "(COPD) includes chronic bronchitis (ICD-9 codes 490-491),
emphysema (ICD-9 code 492), bronchiectasis (ICD-9 code 494), and chronic airway
obstruction (ICD-9 code 496). These diseases are commonly characterized by irreversible
airflow limitation. Some authorities include asthma (ICD-9 code 493) and hypersensitivity
pneumonitis (ICD-9 code 495)" (1)

NIOSH has raised questions about the state governments case against cigarette manufactures
when they say,
"Although 80 to 90 percent of COPD cases are attributable to cigarette smoking [USDHHS
1984], the etiology of COPD is multifactorial. Additional risk factors include occupational
exposures, air pollution, respiratory infection, and genetic factors." (1)

Furthermore, "Unlike some other lung diseases, the risk of HP is substantially lower among
cigarette smokers, perhaps due to smoking effects on lung immunity [Schuyler 1998]. " (1)

As true scientist, they say, "Hypersensitivity pneumonitis (HP), also referred to by the British as
extrinsic allergic alveolitis (ICD-9 code 495), is a group of immunologically-mediated lung
diseases caused by inhalation of a wide variety of antigenic materials [Schuyler 1998]. Most
cases are induced by particulate organic antigens, but some reported cases have been
caused by soluble antigens and low molecular weight reactive chemicals such as isocyanates
and trimellitic anhydride" (1).

As WEF points out Biosolids are an organic product placed on farms and public places,
including home lawns and gardens. NIOSH says, "The disease is often occupationally-related,
and new types of HP continue to be reported as changing agricultural and industrial practices
lead to new types of antigenic exposures." (1)

NIOSH also says, "HP associated with moisture and bioaerosols in buildings (caused by
microbes contaminating humidifiers, dehumidifiers, and heating, ventilation, and air
conditioning systems), and Japanese summer-type HP (caused by house dust contaminated
with Trichosporon cutaneum ) are the most commonly recognized forms of HP." (1)

To counteract this type of sound science, EPA cosponsored a workshop at Duke University
April 16-17, 1998 on odors from sludge. The other cosponsor was the National Institute on
Deafness and Other Communication Disorders (NIDCD). The result of the workshop, "Potential
Health Effects of Odor from Animal Operations, Wastewater Treatment and Recycling of
Byproducts" was published in the Journal of Agromedicine in 2000. According to the chief
architect of the EPA/WEF debunking program, John Walker and Susan S. Schiffman the
articles lead writer, who is affiliated with the Department of Psychiatry at Duke, and Tyler S.
Lorig , who is affiliated with the Department of Psychology at Washington and Lee University,
say "The most frequently reported health complaints include eye, nose, and throat irritation,
headache, nausea, diarrhea, hoarseness, sore throat, cough, chest tightness, nasal
congestion, palpitations, shortness of breath, stress, drowsiness, and alteration in mood." (5)

The EPA implied in 1981, these health effects are imagined results of odors.  The article
seems to reinforce that  view. The article states, "Human health symptoms in humans can
sometimes be unlearned (extinguished) using a technique called systematic desensitization."(5)

Yet, in discussing composting, the article states, "Inorganic compounds of concern includes
ammonia, hydrogen sulfide [H2S], and organic compounds are typically low-molecular weight
organic acids, mercaptans, and amines." (5)

If the rotten egg smell of hydrogen sulfide (H2S) is there, then microorganisms such as
hydrogen sulfide producing enteric bacteria like Salmonella, Proteus, Citrobacter and some
strains of lebsiella are at work. H2S is heavier than air and tends to collect in low places which
creates another acute danger.

The most surprising statement in the article appears to be the result of input from coauthors
(Dennis Schusterman, Division of Occupational Medicine, University of California and C. Mike
Williams, Departments of Poultry Science and Animal Science, North Carolina State
University),concerning toxic organic dust. The article says, "-- at least 25% of pig farmers
suffer from organic dust toxic syndrome which is characterized by periodic, acute febrile
episodes with fever, headaches, muscle aches and pain, chest tightness and cough." (5)

Even without chemicals and disease germs, sludge dust is hazardous. Bradley K. Rein, United
States Department of Agriculture says "Nuisance dusts and gases also are hazards.
Suspended dust particles not containing spores from moldy organic matter are considered
nuisance dusts. Repeated exposure can turn portions of the lung into hardened,
nonfunctioning tissue and cause chronic bronchitis and occupational asthma." (10)

Furthermore Rein says, "A variety of disabling gases, including nitrogen dioxide (NO2),
hydrogen sulfide (H2S), ammonia (NH3), Carbon dioxide (CO2), and methane (CH4), are
produced during many routine operations. Exposure to low levels of NO2, H2S, or NH3 will
produce lung and eye irritations, dizziness, drowsiness, and headaches. High levels of H2S,
particularly, and NO2, secondarily, will quickly render a worker unconscious and death will
follow." (10)

One problem confounding the media and layman trying to follow the science is that new names
keep being attached to old health effects such as farmers lung. As an example, some lung
disease experts now talk about organic dust toxic syndrome, while others talk about toxic
organic dust syndrome Two examples are: Guillermo A do Pico, MD, Professor of Medicine,
Department of Medicine, University of Wisconsin Medical School, who looks at the cause and
effects of "Respiratory hazards of organic dust toxic syndrome exposure" (9), while Kevin C.
Doerschug, MD, Division of Pulmonology, Department of Internal Medicine University of Iowa
College of Medicine, looks at the cause and effect of toxic organic dust syndrome (6).

According to do Pico, Exposure to: "Vegetable: Grains, hay, pollen, cotton, wood, Animal:
Dander, hair, feathers, skin, feces, fungal and bacterial antigens and toxins Insect and mite
antigens", will have these Exposures Respiratory effects, "Mucous membrane irritation,
bronchitis, asthma, nonasthmatic chronic airflow obstruction, organic dust toxic syndrome,
hypersensitivity pneumonitis " (9)

On the other hand, Doerschug, discusses hypersensitivity pneumonitis and toxic organic dust
syndrome. Doerschug says hypersensitivity pneumonitis, "Occurs in up to 8.6% of farmers"
and is "Also responsible for "sick building" syndrome." Furthermore, "There are various
etiologies of hypersensitivity pneumonitis (Table 4-4). In farmers it is caused by inhalation of
Actinomyces spores [thermophilic bacteria], which are present in moldy hay, silage and moldy
grain. " He says, "Onset of illness may range from weeks to years after first exposure to
antigen." According to Doerschug, "Not all individuals exposed at a work site will develop
hypersensitivity pneumonitis. This is in contrast with toxic organic dust syndrome, which results
from inhalation of gram-negative endotoxin and affects all workers at a site." (6)

EPA's David Lewis had to overcome a major obstacle in his study, "Interactions of pathogens
and irritant chemicals in land-applied sewage sludges (biosolids)." Since the EPA had to
approve the study, he could not mention extrinsic allergic alveolitis, organic dust toxic
syndrome or even toxic organic dust syndrome. All he could mention was "aerosols, airborne
dusts, and the role irritant chemicals may play in risks posed by low levels of pathogens."

However, Lewis did do an excellent job of describing the deadly contents of sludge, "The
finished product may contain a wide variety of contaminants with a potential for adverse health
effects [1]. This includes enteric bacteria, viruses, endotoxins, inorganic and organic sulfides,
volatile fatty acids, alkyl amines, and ammonia [2,3]." (2)

Lewis also described the symptoms of disease causing germs and chemical contaminated
dust, "Affected residents lived within approximately 1 km of land application sites and generally
complained of irritation (e.g., skin rashes and burning of the eyes, throat, and lungs) after
exposure to winds blowing from treated fields. A prevalence of Staphylococcus aureus
infections of the skin and respiratory tract was found. Approximately 1 in 4 of 54 individuals
were infected, including 2 mortalities (septicaemia, pneumonia)." (2)

Lewis also described the diseases as best he could under EPA guidelines, "Chemical irritants
of concern with biosolids include endotoxins, lime, ammonia, and alkyl amines. These
contaminants may cause allergic and non-allergic reactions that could contribute to
bronchi-obstructive and inflammatory responses [3]. The senior author and two accompanying
individuals, for example, experienced coughing, burning eyes, burning throat, headaches,
congestion and difficulty in breathing within 1 hour  while conducting a site visit in Menifee, CA.
The visit occurred during a time when residents were reporting these same symptoms.
Although high winds were blowing sand from the treated fields, no odor was evident at that
time. This experience argued against attributing the symptoms to odor-related psychosomatic
responses, which are thought to play an important role in self-reported illnesses associated
with human and animal waste-treatment operations [2]" (2).

One hundred thousand deaths annually from toxic dust related exposure means we have a
major plague on our hands. Unfortunately, with so many International Classification of Disease
codes to use, this number may not be realistic. It is time to make your displeasure known to
Congress and the Senate. --LSI--

1. NIOSH. Chronic Obstructive Pulmonary Disease (ICD-9 Codes 490-492, 494, 496)
2. David L Lewis1, David K Gattie, Marc E Novak, Susan Sanchez and Charles Pumphrey.
Interactions of pathogens and irritant chemicals in land-applied sewage sludges (biosolids).
BMC Public Health 2002 2:11.
3. John Stauber and Sheldon Rampton, book Toxic Sludge is Good for You! -- Lies Damn Lies
and the Public Relations Industry,
4. National Sludge Alliance Fact Sheets,
5. Schiffman SS, Walker JM, Dalton P, Lorig TS, Raymer JH, Shusterman D, Williams CM:
Potential health effects of odor from animal operations, wastewater treatment facilities, and
recycling byproducts. J Agromed 2000, 7(1):1-80
6. Kevin C. Doerschug, MD, Division of Pulmonology, Department of Internal Medicine
University of Iowa College of Medicine. Pulmonary Medicine: Hypersensitivity pneumonitis,
University of Iowa Family Practice Handbook, Fourth Edition, Chapter 4.
7. Swedish National Board of Occupational Safety and Health, ORGANIC DUST IN
Swedish National Board of Occupational Safety and Health on Organic Dust in Agriculture
Adopted 15th June 1994.
8. Sorber, C.A., B.E. Moore, D.E. Johnson, H.J. Harding, E.E. Thomas. 1984. Microbiological
aerosols from the application of liquid sludge to land. Journal WPCF Vol. 56, No. 7:830-836.
9. do Pico GA. "Respiratory Hazards of Organic Dust Exposure: Table 1" Journal of
Respiratory Disease; Vol. 15, No. 6; pg. 553; June 1994.
Guillermo A do Pico, MD
Professor of Medicine, Department of Medicine, University of Wisconsin Medical School, 10.
Bradley K. Rein , United States Department of Agriculture. Health Hazards In Agriculture - An
Emerging Issue. document is 000102014 , a Farm Safety Fact Sheet, United States
Department of Agriculture Extension Service. Publication date: June 1992. Bradley K. Rein,
National Program Leader, Agra-Industry Systems/Farm Safety, United States Department of
Agriculture, Washington, DC,
11. Hazard Information Bulletin , Subject: Fire and Explosive Hazards Associated with Biosolids
Derived Fuel (BDF) and Waste Water Treatment Plants. December 5, 1995. Department of
Labor Occupational Safety & Health Administration . Haug, R.T., Petino, G., Lewis, M.F., and
Hartnett, W.J., (1993) "Explosion Protection and Fire Prevention At A Biosolids Drying Facility,"
Proceedings of the 66th Annual Conference of the Water Environment Federation, Anaheim,
12. Critics Say 1993 Court Ruling Undermines Science By J.R. Pegg,WASHINGTON, DC, June
23, 2003 (ENS),
13. Sludge Spread on Fields Is Fodder for Lawsuits, By JENNIFER 8.
14. Sewage, Suit Links Pennsylvania Boy's Death To Treated Sewage Sludge Spread on Farm,
Toxics Law Reporter, Vol. 18, No. 12, p.225.