Chapter Four


Public perception issues are normally reserved for

public relation firms and there appears to be a public

relations firm involved in this report.  Since the WEF

is supporting this NRC report on public health

perception issues and it did commission the public

relations/lobby firm Powell Tate's (1993) Communication

Plan on Biosolids (CPB), it is clear the purpose of the

NRC report conforms to the plan to "Help advance the

goals of EPA in fostering beneficial use and support

municipal management programs of biosolids." (CPB-p.


Furthermore, "This communication plan developed by

Powell Tate for WEF is meant to serve as a road map for

the Federation as it sets out on its mission of

educating the public and gaining its acceptance of

biosolids." (CPB-p. 1)

Now that we know what the goal of the public

relations campaign is, let's examine the stated

obstacles to get a clear perspective on the NRC report.

"Obstacles" to overcome

(1) "Scientific Obsolescence: with limited

resources available, scientific research can only

address real problems; therefore, once a hypothesis has

been addressed, no further science is conducted."

(CPB-p. 7) Therefore, the need for a new scientific

perception study by NRC and funded by the interested


(2) "EPA's inability to use the term "Biosolids" as

a substitute for sewage sludge: Although research

revealed that government agencies do not have much

credibility on this (sludge) issue, health concerns

regarding biosolids are such that a "higher authority"

is needed to give assurances about safety." (CPB-p.7)

It is apparent that the NRC report is the higher

authority. Plus, Dr. Alan Rubin who supervised the

creation of the sludge rule was loaned to the WEF to

overcome the EPA restriction on the use of the term

Biosolids and actively promote the product.

(3) "Basic lack of public interest: ....Our

research survey found that even many of those who should

know the term "biosolids" because of their involvement

with agriculture and environmental issues, were

unfamiliar with the term." (CPB-p. 8)

That does not appear to be unusual. Many of the

people we have spoken to concerning the sludge rule were

unfamiliar with its provisions and Dr. Rubin even claims

in a memo that he was not aware that the "Quality"

beneficial sludge could not be placed in a legal

landfill under the sludge rule.

(4) "Distinguishing between biosolids and untreated

sludge may be unacceptable to certain parts of the

industry: A powerful message can be communicated that

biosolids represent an advance in technology and are

totally new, environmentally-friendly product. For the

campaign to succeed, there needs to be a clear

delineation between the new, improved product and the

old." (CPB-p.6)

There is a major problem with the recommended

message since the new product has greater levels of

pollutants contaminating it than the old product had and

it can not be put in a surface disposal dump site.

Furthermore, neither the NRC report or the sludge rule

distinguishes between the multiple types of "Class A

sludge" or the different types of "Class B sludge".

(5) "The perception that government is not

adequately regulating this product nor can it be trusted

to do so satisfactorily. Since perception often becomes

reality, we must assume that no matter how much we

stress regulation by the federal government, the public

will not believe that biosolids are well-regulated.

Additionally, this public cynicism also means that the

U.S. Environmental Protection Agency, which on other

issues is usually credible, is not the best primary

messenger on this issue, although the agency may be

influential with state regulators or public health

officials." (CPB-p. 5-6)

It would be hard for any agency to be credible with

a regulation that does not comply with federal law, and

in fact, excludes the products it regulates from the

safety and health provisions of the federal laws. Not

only that, but it becomes very suspect when it loans

its regulatory experts to the organization it is

regulating and encourages the organization to violate

the law in order to obtain unauthorized grant money for

a public relations campaign against the people it is

required to protect, by debunking the sludge horror


(6) "Health and environmental concerns: In our risk

averse society, many are willing--if not eager--to give

the benefit of the doubt to those who voice apprehension

about the safety of biosolids." (CPB-p. 5)

When the EPA states in the preamble to the sludge

regulation part 503 that they are not sure what effect

sludge dumping will have on crops, land, animals or

people it is time to be concerned. Not only that, but

when the EPA risk assessment advises a strict limit,

such as with lead (300 ppm), and then the EPA almost

triples the allowed safe estimated lead level in sludge

(840), the public has a right to be extremely concerned.

It becomes even more of a concern when the EPA

acknowledges it did not regulate 126 priority pollutants

-- because Congress wanted it to regulate a broader

range of substances? Not only that, but the NRC report

acknowledges that the EPA did not address some very

hazardous substances because they only appeared in about

5 percent of the sludges. Are these 5 percent of the

sludges the ones that are killing people and animals?

Now let's examine Powell Tate's list of

opportunities to change the public perception of sludge.


(1) "Biosolids are a resource to be recycled and

reused: Environmental quality continues to be a societal

concern and biosolids can be positioned as an

environmentally friendly process." (CPB-p. 9)

The environmental laws classify sludge as a solid

waste that must be disposed of in a manner which

protects public health.

(2) "Power of recycling message: Recycling has

become a sign of personal environmental commitment.

Awareness of diminishing landfill space and the need to

recycle is on the minds of many individuals -- and in

some cases, their only opportunity to make a positive

impact on the environment. The fact that biosolids

previously were disposed of in ways thought to be

harmful to the environment must be part of the message

that biosolids are the solution, rather than the

problem." (CPB-p. 9)

Since high quality sludge is too contaminated with

pollutants to be disposed of in a legal landfill it is

unlikely that the disposal of highly contaminated sludge

on food crops could be a solution to the problem.  Even

dedicated environmentalists will think twice before

recycling toxic waste on their food crops.

(3) "Good soundbites: "Improving water quality" and

terms related to water quality are good soundbites.

Improved water quality is a positive environmental goal

and we must try to extend its "halo" to biosolids

recycling." (CPB-p. 9)

Since the EPA acknowledges that legal restricted

sludge landfill sites could contaminate ground water, it

is unlikely that unrestricted dumping of contaminated

sludge with a high liquid content on crop land could

improve the water quality.  Furthermore, "halos" should

be reserved for angels and not for creating them.

(4) "Positioning as "water quality professionals":

"Water quality professionals," as identified in the

research, are the most credible messengers. Since the

research did not probe further as to whom respondents

considered "water quality professional," we can promote

our spokespeople as the "water quality professionals" to

be trusted." (CPB-pp. 9-10)

Can a "water quality professional" be trusted when

they advocate putting contaminated sludge on crops as a


(5) "Receptivity to safety-related messages:

Largely because recycling of biosolids is such a

sensible solution, it appears that individuals are

willing to give these messages the benefit of the

doubt." (CPB-p.10)

Sensible solutions are not always sensible when the

scientific evidence and regulations are misused to

promote disposal rather than safety.

(6) "Scientific support: Although the science may

not be recent, it strongly supports the safety of

biosolids recycling. While we did encounter some

skepticism about the science among those we interview,

we should nevertheless use this research to answer

public concerns about health and safety." (CPB-p. 10-11)

There is no scientific evidence which supports the

safety of biosolids used as a fertilizer. The EPA

acknowledges that the scientific data is not available

to support the conclusion and the regulation is based on

EPA risk management policy.

Themes to use in changing public perception

(1) "Beneficial refers positively to biosolids use;

beneficial is also meant to counter concerns about

safety. Addressing safety concerns in the theme more

forcefully will only introduce a negative." (CPB-p. 16)

In effect, the only concern about safety, is that

the name implies that sludge is safe.

(2) "Technology emphasizes, once again, the process

and that the product is treated, as differentiated from

sludge, which is untreated." (CPB-p. 16)

According to the EPA regulation, sludge is treated,

only some sludges are treated to a greater extent than

others and land application is part of the treatment


(3) "Better environment is meant to identify the

process with the drive to be "green"; it is tied to the

fact that improved water quality results in more

biosolids, which are best handled through recycling."

(CPB-p. 16)

A better environment is not produced by using the

most dangerous elements removed from sewage (sludge) as

a fertilizer on food crops.  Treatment plants were built

in the first place to prvent these dangerous elements

from destroying our rivers and lakes.

Messages to change public perception

(1) Top officials at all levels of government,

including public health departments, state and local

agencies that monitor environmental quality, and even

the U. S. Environmental Protection Agency agree that

biosolids recycling is safe." (CPB-p. 19)

Actually, the EPA does not agree that biosolids

recycling is safe. It even acknowledges that the health

of approximately 501 people are at risk.

Not only that, but the Federal Bureau of Land

Management is on the EPA's debunking list because it

does not agree that sludge is safe or that beneficial

use of sludge meets the intent of the law.

(2) "Regulations adopted by the U.S. EPA mandate

strictly monitoring of the quality of biosolids before

it is recycled and set strict criteria for what is in

biosolids. Furthermore, the regulations set out rigorous

guidelines for applying biosolids to different kinds of

land and even to where it can be applied within the

land's boundaries." (CPB-p. 19)

That is true, if the sludge is being placed in a

legal landfill. However, the "exceptional quality"

(1,200 ppm of chromium) sludge can not even be placed in

a sludge only landfill because of the high level

restrictions (600 ppm of chromium) of certain pollutants

and a part 503 landfill does have very stringent

contamination limits within 50 feet of the boundary.

Yet, sludge which is not "exceptional quality"  (3,000

ppm of chromium) can be placed within 30 feet of a river

or lake, even when it is 98 percent liquid.

(3) "Health and safety, Biosolids have been

thoroughly researched by top scientists at the leading

scientific institutions and found to be safe and

beneficial to the environment." (CPB-p. 18)

The NRC is the only leading scientific institution

which has found that sludge is safe and beneficial to

the environment.  This health and safety message also

reflects the same premise as a study done by the

Environmental Institute for Waste Management Studies at

the University of Alabama in Tuscaloosa. The Institute

was funded with a 1 million dollar grant from Waste

Management, Inc., a hazardous waste disposal company.

The Institute produced a study that "concluded that

PCB's, banned in 1976 after being linked to cancer and

liver damage, actually cause no "significant chronic

adverse health effects.""  "We, like private industry,"

said institute assistant director Robert Wells, "We push

it all we can." (From "Final Report - Waste Management,

Inc. By, Edwin L. Miller, Jr., District Attorney, San

Diego, Ca. March 1992)


(1) "The following four most recent studies show

that biosolids recycling has no adverse impact on the

environment or human health. List four favorable studies

with authors." (CPB-p. 18

However, the NRC Committee could not find four

favorable studies. So, they attempted to use what was

available. Currently, a 1.2 million dollar study is

being done at Merco's 128,000 acre Sierra Blanca, Tx.

dump site under the watchful eye of the WEF and EPA.

According to a recent WEF/EPA Fact Sheet for the Merco

project, the sludge is being applied at less than the

recommended rates and cattle grazing is restricted for

two years.  Yet, it would appear this is another study

to prove sludge is safe at recommended rates and when

cattle grazing is restricted by regulation for only 30


(2) "It involves recycling and reuse: it is new

technology that improves on the process our ancestor

used." (CPB-p. 17

Our ancestors lived rather short lives. Plus, they

did not have to worry about toxic and hazardous

substances in their fertilizer. Their biggest worry was

the plagues caused by pathogens that ran wild through

society. Actually, we still have that problem with

contaminated food products that are shipped all across

the country.


The focus of the Powell Tate Communication Plan is

on the "Gatekeepers". "individuals and organizations who

are asked by the public for their opinion on an issue

because of their expertise, authority or position.

Gatekeepers can be teachers, doctors, community leaders,

elected and appointed officials, the media, scientist

and other knowledgeable professionals. Not only does the

public look to them for their opinion on an issue, but

they are used as sources of information by other

gatekeepers -- such as the media -- when they, in turn,

sort out and form their opinions. Educating gatekeepers

on biosolids recycling, therefore, is a critical first

step." (CPB-p. 20)

"Elected officials are an important general

audience for our messages. We have not, however,

included them as gatekeepers because our research found

that they are not credible messengers to others. This

does not mean, however, that they are not an important

audience.  Rather, it indicates that we must educate

them but not expect to use them as messengers."

(CPB-p. 21)

The Powell Tate Program.

"The research found that people know very little

about biosolids and express little curiosity about the

product. As a result, a very real information vacuum

exists that we must fill --- before the critics do."


The Powell Tate Material

"According to the proposal submitted by WEF to the

EPA, a number of informational products are to be

developed, including a video on biosolids, audio and

video PSAs, a brochure and information sheets."

(CPB-p. 22)

"WEF drafts all copy; EPA signs off on the copy and

the brochure is published as a joint WEF/EPA

publication. (This may be a way to deal with EPA's

inability to use the term "biosolids"). If the Agency

finds that it cannot agree to using "biosolids," our

recommendation would be not to proceed with publishing

through the CIC;" (Consumer Information Center, Pueblo,

Co.) (CPB-p. 28)

" this point, our objective is to have a

brochure discussing biosolids published under the joint

sponsorship of EPA and WEF. Although the research shows

that government agencies are not the best messengers,

EPA support for biosolids' safety -- in tandem with

other allies -- can be a powerful tool in this

educational campaign." (pp. 29-30)


"...the difference between spokespeople and third

party allies lies in determining to whom their loyalties

go: a paid spokesperson's primary loyalty is to those

whose top priority is furthering the issue; a third

party ally is first and foremost loyal to the

constituency he or she represents and speaks out on the

issue solely because of its impact on that

constituency." (p. 33)

It is clear that the NRC is a paid spokes-

organization for the EPA/WEF, who's loyalty is to those

whose top priority is furthering the issue of sludge


Powell Tate continues, "In the research survey

recently completed, "water quality professionals" were

viewed favorable as credible messengers on biosolids.

Given the vagueness of the term, we see no reason why

WEF members should not fully adopt this term in

referring to themselves and in all materials produced

for the campaign. Titles such as "wastewater treatment

specialist" or "biosolids coordinator" convey nothing to

the public that is virtually ignorant on the issue."

(p. 33)

The American public may not be knowledgeable on a

specific subject, but it is never ignorant on an issue.

History teaches us that the American public can become

very knowledgeable in a short time when it is concerned

about a subject that affects their life.

Third Parties

"an approach should be considered to an

organization such as the Coastal Conservation

Association, a group located in Houston, Texas, with

approximately 31,000 members. It is in this group's

interest to promote biosolids recycling if only to

guarantee that biosolids are never again deposited in

the ocean." (CPB-p. 36)

It appears that there may be some truth in this

statement, in general.  However, many environmental

groups who fought ocean dumping never envisioned that

the sludge which was destroying the ocean would be

dumped on their own food supplies. The question is,

will they expend the same energy to protect their own

health as they did to protect the health of the ocean?


"An op-ed/letter to the editor placement program

that recruits scientists and public health officials to

byline articles drafted for them and placed in selected

publications." (CPB-p. 41)

Would a true scientist really sell their reputation

to the EPA/WEF for this type of campaign?

Now that we know the NRC report is a part of the

public relations campaign, we can examine the NRC report

with a new insight. There is much to learn from the NRC


The NRC report did clarify the nature of the public

perception problems; "Infectious diseases of the types

that could be associated with municipal wastewater are

under-report and exposures are scattered, so the effects

may well go unreported." (p.96)

Thus, it would appear from a scientific premise,

sludge use is safe as long as only a few scattered

people are harmed?  The EPA's estimate is that 501

human health problems will be scattered across the

United States.

It is apparent the NRC report is part of an attempt

to coverup the EPA's circumventing the protective

clauses of solid waste laws for fourteen years, first

with a beneficial sludge use policy and now with a

regulation, and trying to insulate itself, the states,

and the sludge dumpers from any liability claims for

human health or environmental damage.

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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"