Chapter Four
PUBLIC PERCEPTION ISSUES
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.
12)
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
dumpers.
(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
stories.
(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.
Opportunities
(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
fertilizer?
(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
technology.
(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)
Submessages:
(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
days.
(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.
Gatekeepers
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."
(CPB-p.22)
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)
"...at 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)
Spokespeople
"...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
dumping.
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?
Media
"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
report.
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.
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