POINTS TO PONDER:
WHEN RECYCLING SEWAGE SLUDGE/BIOSOLIDS AND SEWAGE EFFLUENT
Murphy's Law states that: if anything can go wrong, it will.
The first law of recycling sludge/biosolids and sewage effluent:
If disease-causing agents are disposed of on food crops and lawns, there will be deadly
"foodborne" disease outbreaks and deaths, blamed on a failure to properly wash hands or
manure.
1. If, as the Resource Conservation and Recovery Act states, sewage sludge/biosolids (a solid waste) (a pollutant)with
chemical and infectious characteristics (disease-causing agents) may cause, or significantly contribute to an increase in
deaths or an increase in serious irreversible, or incapacitating reversible, illness or pose a substantial present or potential
hazard to human health or the environment when improperly, treated, stored, transported, or disposed of , or otherwise
managed, Why would county and states promote the disposal of sewage sludge/biosolids on school yards, food
crops,grazing land, lawns, gardens, parks, golf courses and forests?
2. If, as the Resource Conservation and Recovery Act states, The term ``solid waste'' means any garbage, refuse,
sludge (pollutants) from a waste treatment plant, water supply treatment plant, or air pollution control facility, why would
EPA claim sludge is excluded from the law based on the exclusion for hazardous waste in domestic sewage in
the sewage pipeline between a residence and the treatment plant?
3. If, as the Clean Water Act states, solid waste, sewage, sewage sludge/biosolids, chemical waste, biological waste,
radioactive waste (pollutants), including disease-causing agents after discharge and upon exposure, ingestion,
inhalation or assimilation into a human (or other organism), either directly from the environment or indirectly by ingestion
through food chains, will on the basis of information available to the EPA Administrator, cause death, disease, behavioral
abnormalities, cancer genetic mutations, physiological malfunctions (including malfunctions in reproduction) or physical
deformations in humans (or such other organism) or their offspring, Why would county and states promote the disposal
of sewage sludge/biosolids on school yars, food crops, grazing land, lawns, gardens, parks, golf courses and
forests?
4. If, as the Clean Water Act states, it is the national policy that programs for the control of nonpoint sources of pollution
be developed and implemented in an expeditious manner so as to enable the goals of this Act to be met through the control
of both point and nonpoint sources of pollution, why would EPA claim sludge is excluded from the law against creating non-
point sources of pollution based on the exclusion for agricultural stormwater discharges?
5. If, as the COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY Act states,
The term “hazardous substance” means, any substance designated pursuant to section 311(b)(2)(A) of the Federal Water
Pollution Control Act [33 U.S.C. 1321 (b)(2)(A)], any element, compound, mixture, solution, or substance designated
pursuant to section 9602 of this title, any toxic pollutant listed under section 307(a) of the Federal Water Pollution Control
Act [33 U.S.C. 1317 (a)], any hazardous air pollutant listed under section 112 of the Clean Air Act [42 U.S.C. 7412], and any
imminently hazardous chemical substance or mixture with respect to which the Administrator has taken action pursuant to
section 7 of the Toxic Substances Control Act [15 U.S.C. 2606], and these substances are in sludge/biosolids, Why would
county and states promote the disposal of sewage sludge/biosolids on school yards, food crops, grazing land,
lawns, gardens, parks, golf courses and forests?
6. If, as the COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY Act states,The term
“release” means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching,
dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other
closed receptacles containing any hazardous substance or pollutant or contaminant, Why would EPA claim
sludge/biosolids is excluded from the law, if you considered sludge disposal to be the normal application of
fertilizer rather than a release of hazardous substances?
7. If, as the EPA sludge rule 503.9(t) states, an organic substance, an inorganic substance, a combination of organic
and inorganic substances (pollutants) , or a disease-causing organism, after discharge and upon exposure, ingestion,
inhalation, or assimilation into a human (or other organism) either directly from the environment or indirectly by ingestion
through the food chain, could, on the basis of information available to the Administrator of EPA, cause death, disease,
behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunction in reproduction), or
physical deformations in either human organisms or offspring of the organisms, Why would county and states promote
the disposal of sewage sludge/biosolids on school yards, food crops, grazing land, lawns, gardens, parks, golf
courses and forests?
8. If, as EPA stated in the preamble to the 1989 proposed 503 sludge rule, five of the listed twenty-one carcinogens in
sludge/biosolids are carcinogenic when inhaled in dust -- Arsenic, Beryllium, Cadmium, Chromium IV and Nickel (hazardous
substances). (FR 54, p. 5777), Why would EPA state in A Guide to the Biosolids Risk Assessments for the EPA Part
503 Rule EPA832-B-93-005, it did not consider any of the cancer causing hazardous metals in sludge to be
cancer causing agents for the risk assessment?
9. If, as EPA stated in the preamble to the 1993 sludge rule, The Agency concluded that Congress intended that EPA
develop the part 503 pollutant limits for a broader range of substances that might interfere with the use and disposal of
sewage sludge, not just the 126 priority pollutants" (hazardous substances)? (FR. 58, 32, p. 9327) , why would EPA
claim that sludge /biosolids was safe to be used by the public as a fertilizer if disposal limits were only placed
on three of the known carcinogens, arsenic, cadmium and nickel and six other hazardous substances/priority
pollutants?
10. If, as EPA claims in the sludge rule 503.13, unlimited amounts of chromium can be allowed in sludge/biosolids used as
a fertilizer by the public, Why would EPA restrict chromium to 600 ppm at the boundary of a regulated and permitted
sludge surface disposal site where public access is restricted?
11. If, as FDA states in the amendments to 21 CFR Part 600, Bacteria produce spores as a means to survive adverse
environmental conditions, while some fungi use them as a form of reproduction. Spores show great resistance to high
temperature, freezing, dryness, antibacterial agents, radiation, and toxic chemicals. Under favorable conditions, spores can
germinate into actively growing bacteria and fungi. Many of these spore-forming microorganisms are pathogenic to humans
and have been implicated in causing morbidity and mortality, [and], For the purposes of these regulations, spore-forming
microorganisms include both the spore and vegetative cells.) [thus], Due to the unique survival properties of spore-forming
microorganisms, current FDA regulations require that work with these microorganisms be conducted separately from
manufacturing operations for other products, Why would county and states promote the disposal of sewage
sludge/biosolids with spore-forming microogranisms as a commercial product on school yards, food crops,
grazing land, lawns, gardens, parks, golf courses and forests with no warning label?
12. If, as FDA states in the amendments to 21 CFR Part 600, bacterial Spores show great resistance to high temperature,
freezing, dryness, antibacterial agents, radiation, and toxic chemicals. Under favorable conditions, spores can germinate into
actively growing bacteria and fungi, Why would county and states promote the disposal of known pathogen
contaminated sewage sludge/biosolids on school yards, food crops, grazing land, lawns, gardens, parks, golf
courses and forests based on the density of pathogenic fecal coliform in the sewage sludge being less than
1000 Most Probable Number per gram of total solids (dry weight basis. = [one million fecal coliform per kilogram]