In a1973 conference on sludge use, USDA's John Walker reported to EPA that USDA
Research at the Beltsville facility showed that mixing lime in sludge or earth as a pathogen
control was only effective for about 30 days. Salmonella bacteria would reappear in tests
after 30 days.
EPA's John Walker  (former USDA employee) and USDA's Rufus Chaney have been key
players in promoting toxic and hazardous sewage sludge as a safe fertilizer. EPA's Alan
Rubin has claimed to be the
Sheik of sludge (look that word up). Rubin was the key
contact for the Water Environment Federation (WEF). He even served two years of his
EPA tenure with WEF promoting sludge disposal as a fertilizer to wastewater treatment
plants and state regulators.
EPA's claim to safety of Class A sludge is that Salmonella be undetectable. What the
USDA and EPA knew was that when the most dangerous disease organism are stressed
by the treatment processes, they become nondetectable - but then can regrow when the
stress is relieved.
Viable but non-culturable states
A phenomena commonly known as viable but non-culturable state has been described for
many bacteria including Campylobacter, E. coli, Salmonella enteritidis, Vibrio cholerae,
Vibrio spp., and Legionella pneumophila (Rollins and Colwell, 1986; Chowdhury et al.,
1994; Roszak, Grimes, & Colwell, 1984; Oliver et al., 1995) . The bacteria are still viable
(exhibit low levels of metabolic activity) but fail to develop colonies on most traditional
solid culture medium. Moreover, pathogens in this viable but non-culturable state have
demonstrated the ability to return to an active potentially disease causing state (Colwell et
al., 1985). However, there is some question as to whether bacteria actually enter a viable
but non-culturable state or whether it is a simple failure of the methods used to recover
stressed organisms. For other pathogens, e.g., Cryptosporidiumand some viruses,
detection methods are unreliable or have not yet been developed (Clancy et al., 1999).
What is important from a public health perspective is that the apparent absence of
culturable pathogens does not  equate to zero public health risk.

Additionally, some viruses have been rendered non-infective because of DNA damage
induced by solar radiation may have enzymes (or their bacterial hosts may have enzymes)
that use other light wavelengths to repair the damaged DNA and thus become infective
again (Weinbauer et al., 1997).

Some bacteria have the ability to colonize equipment, gasket surfaces, and distribution
systems, forming biofilms. Biofilms contain colonies of bacteria surrounded by protective
layers of polysaccharides. Usually these films harbor spoilage bacteria (e.g.,
Pseudomonas spp.) which generally pose little health threat but can contaminate food
and accelerate spoilage. However pathogenic bacteria including Listeria monocytogenes,
Salmonella, E. coli and Legionella can also form biofilms or become entrapped in them
(Cooper, 1998; Lin et al., 1998). Protozoa provide the habitats for the environmental
survival and reproduction of Legionella species which can proliferate intracellularly in
various species of protozoa.

Invasion and intracellular replication of L. pneumophila within protozoa in the environment
play a major role in the transmission of Legionnaires' disease. Growth within protozoa
enhances the environmental survival capability and the pathogenicity (virulence) of
Legionella (Atlas, 1999).

Bacteria in biofilms become more resistant to disinfection, chemicals, and temperature. In
some cases they may enter a viable but non-culturable state which makes them difficult to
detect. Moreover, surfaces where biofilms form may be difficult to test for microbial
contamination or swabbing surfaces may not be efficient enough to dislodge the
embedded bacteria (Cooper, 1998).

Public Health Implications of Water Reuse in the Food and Beverage Industry
Richard Carr
Global Health Leadership Fellow
Water Sanitation and Health
World Health Organization
Geneva, Switzerland
Paper presented at ILSI Seminar: Re-use of Process Water in the Food and Beverage
Industries, November 17, 2000, Pretoria, South Africa
John Walker and Rufus Chaney were on the 503 Peer Review Committee. Both gentlemen
were listed as authors of the
Guide to the 503 Risk Assessment.

Walker and Chaney admit they didn't do a risk assessment on metals because they didn't
consider them to be carcinogens -- causing or inducing cancer. Both admit that they only
looked at the risk from only 13 organics which were either banned, no longer manufactured
or had restricted use.

But they wrote a book about the neat scientific risk assessment they were able to publish
with the help of their partners in the sludge industry.
In 1996, the Nation Research Council, an arm of the National Academy of Science published
a study "The Use of Reclaimed Water and Sludge in Food Crop Production"  which seemed
to indicate that the science behind the part 503 was sound.

It would seem that EPA forgot to tell the scientists there wasn't really a
risk assessment.
These scientists also seemed to think that the worst that could happen to any individual
exposed to sludge or contaminated wastewater was a case of gastroenteritis. Salmonella
and E. coli causes a little more of a problem and could cause death.
EPA and its partners claim there has never been a Peer Reviewed Study showing any
health damage associated with the use of sludge. However, this appears to be another
case of EPA failing to find what it doesn't want to know about. A
quick search finds the
"Neurotoxicity from Municipal Sewage Sludge". Then we find "Risk of respiratory
cancer around a sewage plant in Prato, Italy"

There are also two countries acknowledging  that exposure to sewage sludge dust will
extrinsic allergic alveolitis. Extrinsic allergic alveolitis refers to a group of lung
diseases resulting from exposure to dusts of animal and vegetable origin.

It is also called  
toxic organic dust syndrome (TODS)
On the other hand, our government lumps it all together as:
Chronic obstructive pulmonary disease (COPD) is a group of lung diseases involving
limited airflow and varying degrees of air sac enlargement, airway inflammation, and lung
tissue destruction. Emphysema and chronic bronchitis are the most common forms of

Our medical experts don't know about sludge and say: The leading cause of COPD is
smoking, which can lead to the two most common forms of this disease, emphysema and
chronic bronchitis.

Other risk factors for COPD are passive smoking (exposure of non-smokers to cigarette
smoke from others), male gender, and
working in a polluted environment. Rarely, an
enzyme deficiency called alpha-1 anti-trypsin deficiency can cause emphysema in

The medical experts are so hung up on smoking they rarely consider that a sludge site
and surrounding areas are polluted environments.

No one in government wants to open this can of worms! Just think of the liability.
Emphysema and Chronic Obstructive Pulmonary Disease
Even the Health organization fall prey to bad science and place the major blame for these
diseases on smoking

Several lung diseases are collectively known as Chronic Obstructive Pulmonary Disease
(COPD), including asthmatic bronchitis, chronic bronchitis (with normal airflow), chronic
obstructive bronchitis, bullous disease, and emphysema. About 11% of the population of
the United States has COPD, with the disease becoming increasingly common among
older women. According to the Mayo Clinic, COPD kills 85,000 people a year in the United

The incidence of emphysema is up more than 40% since 1982. Emphysema ranks 15th
among chronic diseases that contribute to limitation of physical activity. About 44% of
those with emphysema report that their daily activities have been limited by the condition.
According to the National Jewish Medical and Research Center in Denver, this chronic
lung disease kills 13,000 people a year in the United States alone, but up to 2.4 million
Americans are estimated to be suffering from this debilitating condition. Emphysema
permanently enlarges and irreversibly damages the alveoli, damages the ends and walls
of the smallest bronchioles (the tiny breathing tubes that branch off from the trachea and
bronchi), and diminishes the elasticity of the lungs.

The writers here claim that toxic chemicals are added to tobacco by the companies. "
chemicals added by tobacco companies for various reasons, and other gases combine to
block the production of alpha-1-antitrypsin (AAT), leading to the destruction of the elastic
fibers of the alveoli."

It would appear the writers don't want to admit that tobacco with take up chemicals from
hazardous waste derived fertilizers, including sludge, at a 20 to 1 ratio,
Then we also have the toxic chemicals on dust in our home.

The study, one of the first of its kind, showed that hidden away in dust balls in vacuum
cleaner bags were 35 toxic industrial chemicals that are legal in products but have been
shown to cause reproductive, respiratory and other health problems in humans or test

The study looked for 44 different chemicals in six classes of chemicals that are common in
consumer products, yet have been associated with reproductive and immune system
problems, asthma and other ill health effects in animal or human studies.

They are phthalates, alkylphenols, pesticides, brominated flame retardants, organotins
and perfluorinated surfactants.

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... The maladies include extrinsic asthma, extrinsic allergic alveolitis, allergic
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