"Sludge disposed of in a sanitary landfill will not harm anyone, nor will it contaminate the food or water supply". (Federal Register (FR.) 58, 32, p. 9375).
"Laws today protect the welfare of research animals, and scientists must comply with strict animal care guidelines", according to the Federal Agency For Toxic Substances and Disease Registry. A federal public health agency of the U.S. Department of Health and Human Services, www.deadlydeceit.com/Ats.html
Why would EPA and the States' decide to kill some of the farmers, their neighbors and their customers by creating open dumps out of farms, home laws and gardens?
The State of Washington Courts have found that the State has no responsibility to protect the lives and health of individuals under the public duty doctrine or the law. (Zander Case, 1995).
Sludge Disposal: Sanitary Landfill--Open Dump--Superfund Site? This (1992) paper examines the Environmental Protection Agency's (EPA) policy of sanctioning the beneficial use of sewage sludge on farmland as a cheap fertilizer and soil conditioner in light of recent revelations of human and animal health problems associated with the use of sludge. (caused by the 21 cancer causing agents and 25 groups of biological agents and:)
The paper concludes that sludge can not be safely disposed of on farmland because: 1) only 28 out of 400 toxic pollutants are proposed for regulation, 2) 15 out of 25 toxic inorganics on the superfund list are not included, 3) Thirty-three pollutants considered hazardous for land disposal are not included.
This is no longer just a farmer's problem. It effects the most basic needs of each and every one of us -- our need for uncontaminated food, clean water and clean air. Although Congress has passed the laws to control the use and disposal of sewage sludge and given EPA a solid waste statute to implement and enforce, the EPA has not adequately addressed the problem. Therefore, it is time that we as concerned citizens do address the problem before more damage is done to the health of those who work on or live around these sites and those of us who consume the food raised there. www.deadlydeceit.com/paper.html
EPA decided to use hazardous waste rules for sludge disposal. By 1983, the EPA decided, "- to avoid conceivable stigmatization, we are willing to re-name recycled hazardous wastes "regulated recyclable materials." () And, in 1985, the "regulated recyclable materials" title was shortened to "recyclable material"." () Not only that, but "---commercial hazardous waste derived fertilizers [which] would not have to undergo chemical bonding to be exempt." from the law. () FR 45, No. 98, Monday, May 19, 1980, p. 33207. FR 48, No. 65, Monday April 4, 1983, p. 14485. FR 50, No. 3, Friday January 4, 1985 p. 646.
This final rule removes chromium in sewage sludge that is land-applied from the list of regulated pollutants for which a removal credit may be available and adds it to the list of unregulated pollutants that are eligible for a removal credit. www.deadlydeceit.com/epa.html
EPA has no chromium limit in sludge/biosolids "fertilizer" yet, For hazardous waste derived fertilizer, "The EPA set its chromium exclusion level at 21.3 ppm for fertilizer with 35.5% zinc content, 67 Fed. Reg. at 48,403/3. Of the twenty commercial virgin fertilizer samples reported by the EPA, six included test results for chromium. Of these six, one had a chromium concentration of 8 ppm; the other five all had chromium concentrations of less than 1 ppm. Data Summary. The EPA's chromium exclusion level thus appears to be more than double the highest virgin commercial sample, ten times the commercial sample mean, and twenty times the commercial sample median." (lawsuit) www.deadlydeceit.com/ChromiumLawsuit.html
House Science Committee Hearing held March 22, 2000. EPA operated true to form during the hearings. Rubin help write a hastily assembled Inspector General's (IG) report which pleaded EPA did not have the people, the money or the power to monitor the sludge disposal program, enforce its guideline, or do any recordkeeping. Nor could it assure the Committee that the public health and the environment was being protected. Not only that, but the report noted GAO had reported these same problems existed in 1990. The report also reiterated the EPA policy of limiting sludge dumping liability by stating that any improper or misapplied sludge use which harmed public health or the environment would be treated as an unknown source of pollution (nonpoint source). This was old news, Including: DR. ROSEMARIE RUSSO of EPA: "EPA failed to conduct research in six areas vitally important to determining the public health risks associated with sludge." DR. JIM SMITH, EPA EXPERT ON PATHOGENS: "conceded that the 503 sludge rule never was subjected to a vigorous risk assessment based on the harmful health effects which may arise from bacteria in the sludge." Attorney Kohn told the Commission Joseph Cocalis of the CDC testified under oath that the 503 sludge rule is indefensible from a public health standpoint ...and that under oath the EPA director of the Ecological Research System said the 503 sludge rule is NOT SCIENTIFICALLY DEFENSIBLE ...people will die from the rule!