The public relations -- public perception factor and
                   mathematical guesstimating dry weight
                                    A creative hoax?
                          Illiterateness or Conspiracy?

Jim Bynum                                                                                                                                        11/7/2007
Retired Safety Consultant

Sludge is generated during the biological treatment of sewage. According to the 1977 United States Patent 4000657
for an Apparatus for measuring the apparent weight of a sludge, "in the case of an increase of the pollution to be
the living matter (biomass) of the sludge, which necessarily increases, also causes an increase of the weight
of the dry material."  The waste industry coined the term
Biosolids as a substitute for sludge. There has been untold
amounts of public money spent in an attempt to convince the public that this biologically active living mass of
pathogenic matter is a safe soil amendment. EPA and the states have created the public illusion that biosolids is a
solid material by having it reported as dry matter based on mathematical best guesstimates. It would appear that
state environmental departments do not understand the subject matter -- that is until they start talking.

For EPA, currently the
legal term sludge and the public relations term biosolids are interchangeable. However,the
term Biosolids is used in an attempt to control public perception as sludge contains chemical and pathogenic
pollutants which, according to
part 503.9(t), the EPA Administrator has documents to show they could cause death,
disease, cancer as well as physical and neurological health damage and abortions by direct exposure, or indirect
exposure through the air, food or water.

However, Pennsylvania officials treat the EPA warning like a joke on the public who doesn't have access to those
scientific documents.
"Permits to use biosolids for mine reclamation won't be rejected unless the public presents
"valid scientific information" that the sludge is harmful, state Department of Environmental Protection officials stated."

Typical ranges of biosolids solids content applied to restoration sites have included liquid sludge at 2-3% or 6-8%
which can easily be pumped, semi-solid biosolids at 8-18% solids which can also be pumped (though less efficiently
than liquids), and solid biosolids cake at 20-40% solids which may be flung from a manure-type spreader or end-
dumped. Application rates are typically calculated on a dry weight basis. This means that, for an average dewatered
biosolids (20% solids), application of 100 dry t/ac [ton/acre] would involve applying 500 wet t/ac [ton/acre] of
material. This is a significant amount of material - almost 5" deep!"

The waste industry is having fun at the public's expense.
"William Toffey, who oversees Philadelphia's waste
program, swears it is safe. He is, in fact, a little giddy about composted human waste. "Biosolids are fun," he said."

For public relation purposes,"
Bill Toffey has written this vision for the Philadelphia Water Department’s biosolids
program: it shall “create no odour nuisances; pose no risk from biosolids-borne pathogens and be a dependable,
affordable, year-round recycling program.” This is the minimum for sustainability;"

For the waste industry,
"William E. Toffey, executive director of the Mid-Atlantic Biosolids Association [MABA], said
he doesn't blame municipalities for adopting local regulations as a tool to deal with residents' concerns. The real
problem, he said, is that residents, farmers and sludge suppliers often don't communicate."We don't tell people what
it is," Toffey said. "We don't tell people where it's coming from. People in the community say, 'This stuff is awful. How
can you do this to us?' "

The real tool the waste industry uses is ridicule toward those who are trying to get the industry to use common
sense, quit faking scientific studies, obey the law, and protect human heath and the environment.  A prime example
is the industry's treatment of Citizens representative, CW Williams, who is the Chair of the Virginia Department of
Health's (VDH) Biosolids Use Regulations Advisory Committee
(BURAC). In an email to Toffey, Alan Rubin, former
EPA super sludge salesman, seeks MABA's help in public ridicule, "See if you can accomodate CW Williams and his
associates to get them into your MABA meeting at Baltimore.  They would provide an "eye opener" for MABA
members who have never seen true "antis".  Great theatre!!!!"

Toffey is correct in that they don't tell people what it is --- (
Virginia is a good example) -- because they don't have
the science to know what is in sludge. The waste industry uses the medical profession's lack of knowledge about
individual exposure to the chemicals and pathogens to victimize the victims by claiming medical symptoms are all in
their mind -- caused by fear and panic.
University School of Medicine, Dayton, Ohio, explain the current concept, "Somatically preoccupied persons have no
genuine physical disorder but manifest psychologic conflicts in a somatic fashion. Somatically preoccupied patients
with more severe manifestations may meet clinical criteria for bona fide psychiatric diagnoses collectively known as
somatoform disorders (i.e., somatization disorder, conversion disorder, pain disorder, hypochondriasis)."

This approach was used in a
waste industry public relation piece attributed to the farmers of Bedford County,
Va. who assumed that their version of the facts would win over hysteria.

Toffey uses this concept to set himself up as a pop psychology expert in the paper
Biosolids Odorant Emissions as a
Cause of Somatic Disease
. He said, as he quotes other Water Environment Federation Public Relations sludge
experts, "The biosolids-aligned experts and their messages on behalf of the wastewater profession have been
consistent and clear -- biosolids does not spread disease-causing organisms and its vaporous emission are not toxic
chemicals (Chrostowski and O’Dette 2002; Blaser 2003; O'Dette 2004). Stories perpetuated on the Internet about
young men dying in Pennsylvania and New Hampshire and about cows dying in Georgia have been thoroughly
addressed by the EPA in its response to the Centers for Food Safety petition as entirely without foundation (Mehan
2003)." "The wastewater profession cannot deny, though, that cases of Class A products meeting the VAR [vector
attraction reduction] standard, yet emitting noxious odors, have occurred, even with some regularity. Examples of
such cases are putrid biosolids compost along highways, noxious advanced-alkaline stabilized biosolids near
elementary schools, and stinky piles of biosolids pellets in a farmer’s field. Each has created community upset and
reports of ill-health, yet each was purportedly a Class A/VAR [vector attraction reduction]-compliant product."
[However, he notes] " Experts to the wastewater profession have not been able to dismiss the role of biosolids in
triggering IEI and psychogenic illnesses.  Evidence supports the third hypothesis, which is biosolids odors trigger
somatic disease. Fear and panic are at play, not biosolids directly."

The waste industry has used this strategy in
Bedford County Virginia where a public relations document attributed
to local farmers was produced which assumed that their version of the facts would win over hysteria.

The waste industry, Mr. Toffey, spreads biosolids polluted with disease causing organisms. Those same disease
causing organisms create toxic chemical vapors such as the extremely deadly hydrogen sulfide (smells like rotten
egg) and the flammable methane, ammonia, etc., which may carry pathogens offsite.  IF THERE ARE NO
CHEMICALS AND NO BACTERIA, THERE IS NO ODOR. Toffey's PR spiel is a little out of date, as well as EPA's PR
spiel about the death of three young people (Daniel Pennock, Tony Behun and Shayne Conner) as well as the
Georgia cattle deaths. In the case of the Georgia cattle, polluted sludge was found to be the cause of death. The
court has ruled that EPA employees don't have discretionary immunity when they use public funds to create fake
studies as two EPA employees did, nor do the scientists who joined the game and are currently being sued.
However, these bad boys can get away with a public funded public relations campaign to cover up the
human and
cattle deaths as well as the general list of victims documented by Ellen Harrison and Helane Shields..

Another "attempt to control public perception is through the use of mathematically created dry weight measurements
in part 503 for liquid sludge. EPA has no enforceable standard when using the metric dry weight milligram per
kilogram (mg/kg) designation.  In  fact, the laboratory metric measurement for dry weights as well as liquids and
pathogens is milligram per liter (mg/L). A liter weighs one (1) kilogram. By using the dry weight measurement, EPA
and the waste industry do not have to account for the chemical and pathogenic polluted water dumped on land with
the biosolids part of sludge.  Out of a gallon of sludge (10 lb) EPA and the waste industry only guesstimate the
chemicals and E. coli (coliform/fecal coliform) for each gram in 750 grams of dry solids -- 26.45 ounces.  Yes, E. coli
is both a coliform growing at 35-37°C  (95-98.6° F) and a thermotolerant fecal coliform growing at 44.5° C. (112.1°
Total coliform are only those disease causing gram negative bacteria that grow at 35-37°C  (95-98.6° F)

EPA's inside joke on
Class B sludge testing is that it gives the waste industry the option of testing 7 samples of
sludge over a period of time and averaging the number for the thermotolerant
fecal coliform E. coli at a most
probable number of two million per gram dry weight.  For Class A, the option is to average the 7 samples of sludge
for an average of 1,000 most probable number of thermotolerant (112.1° F) fecal coliform E. coli per gram of dry
solids or look for the non- thermotolerant (95-98.6° F) coliform Salmonella, among a multitude of coliform bacteria, at
an average of  less than three Most Probable Number per four grams of total solids dry weight.  The simple fact is
that if Salmonella doesn't grow at the tested temperature, the waste industry can not find it.

In  1973,  
John Walker, retired head of the EPA sludge PR program and now being sued in Georgia, who was with
the USDA at that time, explained to EPA that non-detection of Salmonella did not mean the bacteria were dead.  
USDA research showed that liming sludge, or liming the soil, only inactivated Salmonella for about 30 days. Then
there was regrowth to the original levels.. EPA also noted in the 1989 proposed 503 sludge regulation that there
could be explosive regrowth of Salmonella. (National Association of State Universities and Land Grant Colleges,
1973)". Walker recently lost his federal discretionary immunity for overseeing a fake study using federal funds.

In 2006, EPA states, "Composting is not a sterilization process and a properly composted product maintains an
active population of beneficial microorganisms that compete against the pathogenic members. Under some
conditions ,explosive regrowth of pathogenic microorganisms is possible." "In addition to odors, other bioaerosols,
such as pathogens, endotoxins, and various volatile organic compounds, must also be controlled."

D. Strauch in his 1991 paper, "Survial of pathogenic micro-organisms and parasite in extreta, manure and sewage
reported that "most pathogenic agents can survive the treatment process" and the sewage treatment
process causes some of the pathogenic disease organisms to be absorbed or enclosed in faecal particles
during the treatment process. "Therefore," according to Strauch, "sewage sludge is rightly described as a
concentration of pathogens."  "In any case" Strauch said, "the agricultural utilization of hygienically dubious sewage
sludge poses a risk for the whole national economy."

"EPA's microbiologist David Lewis discovered lubricants as well as absorption caused laboratory testing problems. .
"According to Lewis, "standard test methods underestimate the number of water repellant contaminates. The water
repellant lubricants such as silicon and petroleum products cover the pathogens and prevent them from being found
by standard test methods. It was only when he dissolved the lubricants with acetone or other solvents, that the
pathogens showed up in tests." "The problem of pathogen detection in sludge, according to Lewis, "is that the
sewage treatment process changes the outside crust of the aggregates in sludge and only the pathogens on the
outside of the aggregates are measured by standard tests." He says that most of the microbes are trapped inside
the aggregates.  When ultrasound was used to break open the aggregates of sludge the trapped microbes were

In June 2006, the Water Environment Federation's Research Foundation (WERF) released a study which seems to
have rediscovered the same information: "In a recent study of anaerobically digested solids from seven wastewater
treatment facilities, counts of fecal coliform bacteria increased after dewatering at four of the facilities tested.
Immediately after centrifugation, fecal coliform counts increased from very low or nondetectable levels, often by as
much as several orders of magnitude, at the four facilities  where increases were observed."

It appears the waste treatment industry can no longer ignore the citizens who are exposing their lack of science and
in fact, made sure they received this information personally. The real reason, after 40 years, the industry is looking
for more public money to study its lack of waste treatment science.  But then the industry has been using a 100 year
Biochemical Oxygen Demand (BOD) test to prove the sewage treatment plants work.

Tim Loftus, Chief Chemist and Industrial Pretreatment Coordinator at the Webster-Dudley Wastewater Treatment  
and a member of
NEWEA Lab Practices Committee, states, "Obviously, the BOD test is not the most scientifically
based test we perform. As such, it has many problems associated with it. The most significant problem is that the
results come five days after the fact. By that time you’ve already discharged any problem wastewater. Then the
variability of the seed must be constantly monitored. Sometimes the bacteria wants to work, sometimes they don’t.
Again, by the time you find out, it is five days too late. Some analysts support the use of respirometry to give more
timely results, but regulatory agencies have not fully accepted the methods yet so NPDES permits continue to
specify that we perform the standard 5-day BOD test."

Loftus adds, "There is no absolute BOD value of a sample as there would be for say copper or lead. BOD results
are test defined. In other words, BOD values are based on the parameters of the test method, not on any “true” BOD

Retired professional waste water engineer,
Peter Maier said, "The largest mistake wastewater engineers (private
and government) made in the past was not to apply the BOD test correctly and as consequence we never have
been able to evaluate the real treatment performances of the different sewage treatment systems. You could do
what you want, because a real cost-benefit ratio analysis was impossible." But that is not all according to Maier,
"It was estimated that after EPA allowed the inhibited BOD test( the same BOD test, except with a certain chemical
added to kill selectively only the autotrophic bacteria (nitrifiers)) 60% of all the sewage treatment plants out of
compliance got into compliance by adding this few cents of chemicals to the test.  By doing so, EPA lowered the goal
of the Clean Water Act from elimination (100% treatment) to a measly 85% of 40% = 35 % treatment and ignored all
the pollution caused by nitrogenous (urine and part of the protein) waste.  EPA did lower the goals without even
informing the Congress."

EPA used the same type of strategy in developing the
E. coli fecal coliform test. They figured out a way to
surppress all pathogenic
bacteria except the target E. coli organism.

"In   May 2006,  
University of Minnesota researchers published data showing that extremely high numbers of
multi-drug resistant bacteria   in effluent (treated water) at high levels are being released into the environment from
highly efficent, award winning, sewage wastewater treatment plants. Researchers were very concerned when they
found extremely fast transfer of the drug resistant gene between bacteria in the treatment plant which confirmed EPA
studies fron the 80s. They appeared to be somewhat confused because the bacteria taken out of the treated water
were not detectable in sludge."

"The second largest mistake, especially in the US," according to Maier,  "is the fact that Congress allocated federal
funding (85%) for the construction of new sewage treatment plants. This led to cities building facilities, supposedly
for the future, without any justification, while offering this additional capacity to industries.  The claim now is that
these industries have to provide a certain pre-treatment, but those requirements often have little to do, with what
type of waste is in their wastewater.  Most cities are very secretive about the arrangements they have with industries
and these industries now refuse to treat their own wastewater."

In discussing sludge dry weight, Maier said, "When they calculate the dry solids, it is assumed that the specific
weight of the solids are the same as water and you can make an argument that this is not always the case, but then
you work with so many assumptions that in any calculation of, especially sludge disposal, the efficiency of the
dewatering equipment is much more important. Here, especially when belt presses are used, with their high cost of
polymers, communities skip on the chemicals and then have to deal with much more sludge."

Figure 1: Mathematically Metric conversion.

EPA uses Dry tons for analysis and reporting  as dry weight based on the weight of water - not sludge.  EPA formula
to change gallons to dry tons uses a specific gravity of water (1.0)  rather than the accepted  specific gravity of
sludge (1.31).  (Gallons X 8.34 Lbs./Gallon X % Solids) Divided By 2000 Lbs/Ton = Dry Tons

The difference in specific gravity  of sludge vs water is 100 tons in the following examples:

EPA example using water weight:
A wastewater treatment produces 2,000,000 gallons of biosolids a year at 6% solids. How many dry tons are
produced. (2,000,000 X 8.34 X 0.06) / 2000 = 500.4 dry tons

Real world Example using sludge weight::
A wastewater treatment produces 2,000,000 gallons of biosolids a year at 6% solids. How many dry tons are
produced. (2,000,000 X 10 X 0.06) / 2000 = 600 dry tons

* MPN - most Probable number

Figure 2: Biosolids is not a biosolid until the liquid is ignored and it is reported as a dry weight.  

100 %---------------------------------------------------------------------------------------------------------------------------------

90 %

80 %












VA Biosolids Use Regulations: 12 VAC-585-470-D: (i) liquid sludge defined as sludge with less than 15%
total solids;  (ii) dewatered sludge defined as 15% to 30% total solids; (iii) dried sludge defined as with
more than 30% solids.

VDH uses 4 wet tonnage (25% solids) = to 1 dry ton when generally calculating.

Application limits, with exceptions of A and EQ,: Liquid shall not exceed 14,000 gallons per acre; Dry not
to exceed 15 (dry) tons per acre.

However, we may not be able to believe any Laboratory report:
"EPA Sludge Coordinator John Dunn has stated, "if you send a sample to three different labs, you get back
three different results." This example was illustrated when Kansas City, Missouri and the State environmental
department split a sludge sample. The results were that Kansas City reported the pollutant levels in parts per million
while the State reported the pollutant levels in parts per billion.

An interesting point. In reviewing Kansas City, Missouri's sludge disposal records from a secondary treatment plant
the solids ranged from 1/2 percent to 4 percent.   The implication of Part 503 is that 96 to 99.5% water in sludge
doesn't run down hill.

Another point is that there is no enforceable standard for dry weight conversion.

As an example, using the EPA standard leach rate test (TCLP) lead at 5 ppm in either liquid or dried sludge makes
it  a hazardous waste.  The accepted leach rate conversion factor is 20 parts total lead to 1 part leaching out of the
whole. In dried unlabelled Class A EQ sludge biosolids with 300 ppm of total lead, we could expect it to be 3 times
the hazardous waste level. For Class B at 840 ppm of total lead, we could expect it to be 8 times the hazardous
waste level.  

In looking at public records, generally we have no way of knowing where the numbers are for liquid or dry weight
measurements.  If it is an enforceable standard test (liquid or dry) it will be mg/L (1,000 gram), if it is the
nonenforceable total metals test (liquid or dry) it will be mg/kg (1,000 grams).  To confuse the issue even more, the
results may be mislabelled as it was in Kansas City, Missouri.

The records show that
Kansas City's Blue River wastewater treatment plant sludge was piped to the Birmingham
site for disposal in 1994, with arsenic levels as high as 589 mg/kg vs the 75 mg/kg allowed for beneficial use. In
September 1997, it was reported that the monitoring well, which exceeded NPDES limits for arsenic, had done so a
number of times in the past. In spite of the high levels of arsenic disposed of on the site, Kansas City wrote,
"It is our feeling that the Birmingham land application program did not cause this violation."

The most interesting part of the Kansas City's 1995 sludge report was a comment by Kansas City explaining, "We
will be working with our laboratory in the future to obtain lower detection limits for arsenic and
"Apparently Kansas City's laboratory did comply with the wastewater divisions request and it obtained
much lower detection limits in 1996.  For the 12 months of 1996, there was a dramatic drop from the 105.263 mg/kg
arsenic levels in 1995. According to the reports, during 1996, the arsenic levels only ranged from 1.23 mg/kg to a
maximum of 5.261 mg/kg with  an average of 3.02 mg/kg.  However, molybdenum levels in the sludge ranged from a
low of 51.02 mg/kg to a high of 263.16 mg/kg with an average of 185.64 mg/kg. It would appear that
someone forgot to tell Kansas City's laboratory that the regulated ceiling level of molybdenum for disposal was only
75 mg/kg."

The accepted mathematical hazardous metals leach rate conversion is 1 part hazardous metal leaching out of 20
parts total metals.

It would appear the Kansas City Laboratory used the hazardous metals test (TCLP) leach rate of 1  part per million
(ppm - mg/L) leaching out of 20 ppm total arsenic to come up with the new figures (105.263 / 20 = 5.263 mg/kg

New York City had a similar problem with the lead in sludge it shipped to Texas.  In one study, New York City sludge
averaged 6,400 ppm total metals. By the time the sludge got to Texas, lead was reported as 193 ppm. Perhaps
pretreatment did cut the lead level from 6,400 ppm  to 3,860 ppm / 20 = 193 ppm. In fact, the Water Environment
Federation (WEF) fact states the TCLP test was used for both metals and pathogens.  

"According to a New York City study, pretreatment by industry would not help New York City control the toxic metals.
"The 1970 to 1972 study of the sources of these heavy metals in New York City waste-water concluded that even
with zero discharge by industry, 94 percent of the zinc, 91 percent of the copper, 84 percent of the cadmium and 80
percent of the chromium being discharged would continue to be discharged by sources virtually immune to treatment
(Ref. 1)." (Wat. Sci. Tech. (1987) Vol. 19, No. 9. p. 133)

They tell us that EPA and state regulations protect public health, yet: "according to the [WEF] Fact Sheet, "In
September 1993, a series of human errors in New York City and in Texas led to the application of nine rail
containers of biosolids that had failed to meet the detention requirement for PSRP [Process to Significantly Reduce
Pathogens] (." (p. 3)

"Not only that, but, "In Texas, the regular testing for the presence of pathogen indicators has occasionally revealed
varying levels above the federal and state regulatory limits, causing concern about pathogen regrowth during
However, an independent analysis by Alternative Resources, Inc., of Stroudsberg, Pa. determined that the
variations were most likely caused by inconsistencies in the sampling and analytical methods at the five separate
labs conducting the analysis."
(p. 3)

EPA and the waste industry can not get a simple test done right, and yet, they try to make us think we are crazy and
the sickness is all in our mind. They are laughing at the sick and dying all the way to their retirement. Just ask super
sludge salesman Alan Rubin how much fun he's having in retirement at our expense.
Average solids
level are below 5%
Liquid sludge (i)
bulking agents
Dewatered sludge
Dried sludge -
sludge cake (iii)
Liquid, dewatered and dried
sludge reported as dry weight
ounce=28.34 grams
Pound=453.59 grams
Dry weight
Class B - dry weight
E.coli -fecal coliform
2 million per gram MPN*
Liter- water
Gallon water
Gallon sludge weight
6% solids
10 lbs
0 - liquid - <8.34 lb
solids - >750 gram =
>1.65  pound =
>26.45 ounce
liquid not regulated
1,500,000,000 cfu mpn?