Lies and Lying Liars
Had to steal the title from Molley Ivins
By Jim Bynum 11/04/2007
Retired Safety Consultant
Retired EPA Employee, Alan Rubin requested that the Mid-Atlantic Biosolids Association invite some
sludge opponents to the November 7, 2007 meeting to poke fun at them:
Bill: 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!!!!
Found on Mid-Atlantic's Biosolids Association website
http://mabiosolids.org/index.asp
A little public relation piece courtesy of the biosolids "experts" who would like the public to think sick people who have
been exposed to sludge biological solids are psychotic hypochondriacs. If a farmer
(a PR gatekeeper) did in fact write this article, then the 1994 EPA funded Public relations program run by Water
Environment Federation members paid off and is still running full bore. The basic premise is that those neighbors
who are sick and opposed sludge use are hysterical. On the other hand a wise person once said figures can lie and
liers can figure, but they can not produce a single study "showing scientific research and practical experience
demonstrate the complete safety, environmental compatibility and agricultural benefits of biosolids"
A message from the farmers of Bedford County [Virginia]
The Truth about Biosolids
For the past few months, we’ve watched in silence as misinformation has been spread about the land application of
biosolids in Bedford County. Since biosolids have been applied to Bedford farms for more than 25 years without one
documented case of harm to people, animals or the environment, we assumed that the facts would win over hysteria.
We failed to understand, however, the power of lies that are repeated over and over again without challenge. And we
failed to understand that our silence was misinterpreted by some as an inability to respond.
On Monday, March 26, we broke our silence and presented the facts to the Bedford County Board of Supervisors. As
we explained that night, the overwhelming body of scientific research and practical experience demonstrate the
complete safety, environmental compatibility and agricultural benefits of biosolids.
We want to engage our friends and neighbors in Bedford County in a rational discussion of biosolids and the many
benefits to our community. We believe most people are fair minded and willing to consider the facts. This ad, paid
entirely by Bedford County farmers, is the first of a series where we plan to present those facts.
But first, we need to answer some of the “fiction” that has been spread in Bedford County.
Fiction: Biosolids are “treated human waste.”
Fact: That’s like saying this newspaper is printed on dead trees. Just like any other manufacturing process, the final
product of biosolids is very different from the original materials. Modern wastewater treatment uses beneficial
organisms to consume waste material and pollutants as food and then convert it into cellular body mass. A simple
explanation is that the “good bugs” eat the “bad bugs.” As the organism population grows, a portion is removed to be
“digested,” which starves the process of new food and forces the organisms to consume themselves. After digestion,
lime is mixed with the biosolids to meet EPA pathogen standards and to further reduce the attraction of “vectors,” such
as flies or other pests.
Factual Reality: If the organisms consumed themselves, there would be no need to for EPA to allow two million fecal
coliform (thermotolerant gram negative E. coli) per gram of sludge biological solids (a living biomass) to prove the
safety of sludge. That is about 56 million thermotolerant E. coli per ounce of dry weight sludge. The regulation
actually ignores the large volume of liquid in sludge biological solids. The fecal coliform tests do not enumerate the
gram negative bacteria (Total coliform) , gram positive bacteria, viruses, helmeths, protozoa, or fungus.
Furthermore, adding lime to sludge biological solids (biosolids) raises the pH to 11 or 12 which converts chromium
three to chromium 6, a carcinogen, which is readily taken up by crops. While lime treatment does inactivate bacteria
for a short time, USDA employee, John Walker, reported to EPA in 1973 that Salmonella recovered to the original
numbers in about 30 days. Apparently, EPA hired him and put him in charge of the sludge Public relations campaign
to convince the public and farmers that sludge was safe if it was called biosolids.
Fiction: The biosolids storage site on Otterville Road is a “pond.”
Fact: The site is not a pond. It is a three sided bunker pit with a compacted clay base that was used to store
dewatered biosolids. The site was designed to conform to state regulations and has been inspected numerous times
and found to be in compliance by the Virginia Department of Health (VDH) and the Virginia Department of
Environmental Quality (DEQ).
Factual Reality: VA Biosolids Use Regulations: 12 VAC-585-470-D classifies dewatered biosolids as 15 to 30% total
solids. Since solids settle to the bottom, the 70 to 85% liquids on top would appear to create a pond or a
sludge lagoon.
Fiction: The site “overflowed” and deposited biosolids into a fork of the North Otter River.
Fact: The DEQ investigated this claim in February 2006 and concluded that the site was operating properly and that
there was no impact on the stream. The DEQ investigator concluded: “In summary, I found no biosolids deposited
along the potential flow path, or any other clear evidence that the facility was discharging to a stream.”
Factual Reality: DEQ can not afford to find a problem with any sludge site. 'In Virginia, about 72-hundred miles of
river are polluted by fecal bacteria or other substances." "State regulators have proposed increasing the acceptable
amount of fecal bacteria [E. coli] in Virginia's streams, rivers and lakes."
State Department of Environmental Quality staff members, who advise the board, have said it
makes sense to relax the bacteria limit because it's almost impossible to meet the standard in
many waterways. DEQ staffers have said the relaxed limits would still protect the public.
Fiction: Untreated sludge was stored at the Otterville storage site.
Fact: No untreated sludge has ever been stored or land applied in Bedford County by permitted land applicators.
Federal and state laws prohibit the land application of untreated sludge and only biosolids that meet all federal and
state regulations are stored and land applied. Biosolids are constantly monitored and undergo extensive testing
before they can be land applied. They must meet federal and state regulations for pathogen reduction and other
potential pollutants.
Factual Reality: As EPA now confirms, the legal name is sludge, not biosolids. A pathogen reduction to two million
(dry weight) E. coli per gram of sludge is simply a guesstimate at best. There is 28 grams per ounce which equals
56 million E. coli per ounce. But the regulation don't address the 70 to 85 % liquids being dumped on the ground. The
regulation does not address most potential pollutants. As an example, chromium is not addressed in part 503.13,
(which originally allowed 3,000 ppm), but, in 503.23 chromium is restricted to a maximum of 600 ppm in a surface
disposal site.
Fiction: Biosolids are toxic.
Fact: The U.S. Environmental Protection Agency has determined that the regulated use of biosolids is safe for land
application as a fertilizer and soil amendment. By federal definition biosolids are not toxic.
Factual Reality: There is no federal definition stating biosolids are not toxic! That definition was created by
the waste industry. Part 503.9(t) does state that the EPA Administrator does have documents on file which show
exposure to the pollutants in sludge (i.e inorganic and organic chemicals, disease organism or any combination, could
upon either direct exposure or indirect exposure through air, food or water cause death, disease, cancer, physical,
neurological problems and even abortion. Part 401.15 lists the toxic pollutants which may be found is sludge
biological solids. Part 116.4 lists the hazardous substances which may be found in sludge biological solids.
Fiction: Dr. Don Stern, Virginia Department of Health, was quoted as saying that exposure to biosolids could
“endanger people with asthma, COPD, or other existing pulmonary conditions.”
Fact: Dr. Stern was contacted by phone at his office in the Richmond Department of Health on December 4, 2006. He
expressed surprise at the quote and stated that it does not represent his position on biosolids.
Factual Reality: Since the Department of Health has been promoting and permitting sludge sites, it is understandable
that Dr. Stern might not admit to such a statement. Before EPA released its sham of a regulation in 1993, the
Australian government issued its "Statement of Principles concerning EXTRINSIC ALLERGIC ALVEOLITIS in the
Veterans Entitlements Act" 1986. The government recognized that working with sewage sludge was a very dangerous
occupational risk. www.rma.gov.au/SOP/97/057.pdf In Canada, the government recognizes that exposure to dried
sludge/biosolids will cause the respiratory disease "extrinsic allergic alveolitis". It is called: Sewage sludge disease
www.ccohs.ca/oshanswers/diseases/alveolitis.html Extrinsic allergic alveolitis is better known is COPD.
Fiction: Biosolids cause health problems for humans and animals.
Fact: In every case where there has been an official investigation of health claims, no link has been established
between biosolids and health effects on humans or animals. Two claims of human deaths made in Pennsylvania were
investigated by the state Department of Environmental Protection, which found no link to biosolids. Similar claims of
cattle deaths in Georgia were investigated by the state and the EPA and were found to be the result of a common
dairy disease called Johne’s disease.
Factual Reality: There has never been an official investigation by public officials or even a risk assessment. Public
officials can not afford to investigate damages from a program they promote and permit. The fact is they are killing
us, pandemics are running wild and they don't know how to stop it. Chemicals were involved in the Georgia cattle
deaths rather than Johne's disease. Johne's disease has been known for 90 years or so, but like E. coli 0157:H7 and
Salmonella, it wasn't a such common disease before the sludge dumping program began. "Johne's disease
(pronounced "Yone-es") or paratuberculosis is an incurable wasting disease of adult cattle that is being increasingly
recognized in the United States. Since prevalence rates in U.S.-slaughtered cows range from 2 to 18 percent, Johne's
disease is now considered a major problem." Human health problems and deaths have been associated with sludge
biosolids and compost. Cattle health and deaths have been associated with sludge
Fiction: The anti-biosolids ordinance proposed for Bedford and Campbell counties will withstand legal
challenge.
Fact: Ordinances written by the Community Environmental Legal Defense Fund (CELDF) in Pennsylvania have been
invalidated in Federal Court in Pennsylvania and are currently under legal challenge by the Attorney General of
Pennsylvania. The Pennsylvania General Assembly passed a law in 2005 specifically authorizing the Attorney General
to sue townships that pass such anti-farming, antibusiness, anti-biosolids ordinances. The courts in Virginia have
consistently ruled that counties may not pass ordinances that conflict with state regulations that regulate the land
application of biosolids.
Factual Reality: It is interesting that the state revised it's solid waste law to comply with the EPA policy regulation part
503, which promotes open dumping of solid waste, which is a prohibited practice under the federal solid waste laws.
Furthermore, state law now promotes non-point sources of pollution on agricultural land under an exception in the
Clean Water Act for agricultural stormwater runoff. When the sludge finally hits the fan, the state will be stuck with
the total cost, because it does not have a federal approved solid waste management plan and by adopting 503 they
can not request superfund cleanup monies.
Fiction: Diseases can travel through the air from the land application of biosolids.
Fact: Research conducted by the University of Arizona has demonstrated that disease-causing pathogens do not
travel through the air from biosolids land application sites and therefore cannot cause illness. A separate study by the
University of Arizona found that Staphylococcus aureus, a disease causing pathogen, was not present in biosolids. A
study by the National Academy of Sciences found no evidence that exposure to biosolids causes illness.
Factual Reality: Neurotoxicity from Municipal Sewage Sludge By Raymond Singer, Ph.D.October, 1999
Based on results of the Neurotoxicity Screening Survey, symptoms consistent with neurotoxicity
were found in all who completed the test. The two children born and raised on the farm have been
classified by their schools as mildly retarded and having attention-deficit disorders, although there
was no family history of these illnesses. www.expertlaw.com/library/toxicology/sewage_sludge.html
In a 1985 study, (In general, the densities of microorganism-containing aerosols were higher at
night than during the day.) In the University of Arizona study it is claimed, "All samples were analysed for the
presence of HPC bacteria, total coliform bacteria, Escherichia coli, Clostridium perfringens, coliphage, enteroviruses,
hepatitis A virus and norovirus. Total coliforms, E. coli, C. perfringens and coliphage were not detected with great
frequency from any sites," Staphylococcus is an HPC bacteria as well as are all of the other pathogens and bacteria
in nature. Did they really test for all pathogens? The University of Arizona study had two major flaws: ."
"Samples were collected for a total of 20 min or c. 250 l of sampled air."'All samples were heat shocked at 70C for 20
min prior to sample analysis." 70 degree Celsius = 158 degree Fahrenheit. EPA claims bacteria are
inactivated at 55 degree Celsius = 131 degree Fahrenheit. Coliform bacteria are tested at 35-37 C = 96-
98.6 F. and fecal coliform are tested at 44.5 C = 112.1 F.
Fiction: Runoff from land-applied biosolids causes stream and well pollution.
Fact: State regulations require buffers between land application sites and streams and wells and impose other
restrictions that limit the possibility of harm to waterways. University research, including years of research by Virginia
Tech, indicate that biosolids are actually less susceptible to runoff than commercial fertilizers. The DEQ has
investigated numerous claims of biosolids runoff and found no evidence of problems.
Factual Reality: As noted above about 72-hundred miles of Virginia rivers are polluted by fecal bacteria [E. coli] or
other substances." Actually Virginia recognizes the federal Clean Water exemption for stormwater pollutants washing
off agricultural sludge disposal sites into the waters of the United States. In Kansas City, Missouri, thermotolerant fecal
coliform (e. coli), and the coliforms E. coli and Salmonella was documented to have washed off the City's sludge site
unto a neighboring farm. A year after sludge disposal, both E. coli and Salmonella were found at 800,00 cfu each. In
one place where sludge had not been dump in over six years thermotolerant E. coli was found at 650,00 cfu.
Fiction: Land application of biosolids lowers property values.
Fact: There is absolutely no evidence for this claim. In fact, farms that use biosolids are more productive, which
increases their value. Biosolids have been land applied throughout Bedford County since the early 1980s, during the
same time that property values in the county have skyrocketed. In 2006, the 5,500-acre Curles Neck dairy farm in
Henrico County, near Richmond, was sold for $25 million. Biosolids have been land applied on this property for years.
Factual Reality: The question is, was there a disclosure for lead contamination. It appears we have a don't ask,
don't tell policy in Virginia. Under part 503, EPA will allow 840 ppm of lead in sludge with a total disposal rate of 300
kilograms per hectare.
Lets see: EPA said small quantities of lead was Bad in paint!. EPA said small quantities of Lead was Bad in Gasoline!
EPA said small quantities of lead was Bad in shot gun shells! EPA said small quantities of lead was Bad in the homes
and yards of Herculaneum, Missouri!
Federal law requires that individuals receive certain information before renting or buying a pre-1978 housing:
Residential Lead-Based Paint Disclosure Program.
LANDLORDS have to disclose known information on lead-based paint and lead-based paint hazards before leases
take effect. Leases must include a disclosure form about lead-based paint.
SELLERS have to disclose known information on lead-based paint and lead-based paint hazards before selling a
house. Sales contracts must include a disclosure form about lead-based paint. Buyers have up to 10 days to check
for lead hazards.
Fiction: Biosolids hurt tourism.
Fact: Do tourists visit Bedford County to see subdivisions or do they want to see green pastures with healthy cattle
and horses? The productive farms that result from 25 years of biosolids application have contributed to the beauty of
Bedford County, preserved our green space and made our county more attractive to residents and tourists alike.
Fiction: Nobody knows what’s in biosolids.
Fact: Biosolids are tested extensively for pathogen levels and hundreds of other potential pollutants. These test
results must be reviewed by the Virginia Department of Health before the biosolids are approved for land application,
regardless of whether the biosolids are produced within Virginia or in some other state. In addition, land application
companies and local county biosolids monitors routinely collect samples of biosolids and submit them for analysis by
certified laboratories. Other safeguards are also in place to ensure that biosolids are safe. Industries must pre-treat
their effluent to remove heavy metals and other pollutants before discharging into the municipal wastewater treatment
system. Cities also have restrictions on hospital and morgue discharges.
Factual Reality: Sludge biological solids testing is based on taking seven grab samples over a period of time and
averaging the resulting test numbers for nine toxic heavy metals and E. coli. There is no reguirement for testing
hundreds of potential pollutants unless it is going in a landfill. While industries are "required" to to pretreat their
effluent the waste treatment plant are allowed to issue pretreatment credits under part 403, appendix G, for those
same nine metals, plus chromium at extremely high levels, if the sludge is to be land applied.
As noted above, there is no pathogen test required. Thermotolerant E. coli testing at 112 degrees F. is done to
indicate the possible presence of coliform pathogens which are revealed when tested at 96-98.6 degrees F.
Fiction: Biosolids contain dangerous “heavy metals.”
Fact: Many of the so-called “heavy metals” in biosolids are actually essential plant nutrients. In addition, some of the
minerals in biosolids are needed for animal health, including humans. Many of these “heavy metals” are found in
multivitamins, such as zinc, selenium, copper, chromium and nickel. The amount of these minerals in biosolids is very
small and has decreased significantly over the years because of pre-treatment requirements. These levels are far
below any levels that could be harmful. It has been estimated, for example, that you would have to eat 214 pounds of
biosolids a year just to get the recommended requirement for zinc.
Factual Reality: Heavy metals are deadly as noted by government studies: Arsenic, Cadmium, Chromium
six, copper, Lead, Mercury, Nickel, Selenium, Zinc, . Lets not forget Beryllium, and Thallium, etc. The
pretreatment requirements did not lower chromium levels. In 1995, EPA removed chromium at 3,000 ppm
from the part 503 and in 1999, EPA allowed removal credits of 100,000 ppm if the chromium was land
applied under part 503. The hazardous waste level is five (5 ppm) parts per million.
The Recommended Dietary Allowances (RDAs) for zinc is 11 mg/day for men and 8 mg/day for women. One kilogram
of sludge biological solids may contain 7500 mg/kg of zinc (2.2 pounds -not 214 pound) . For a man, that is 681 days
worth of RDA's. For a woman that is enough RDAs for 931 days.
The cost of this advertisement was paid by the farmers of Bedford County.
Coordinated by Don Gardner, DVM.
I have to wonder if Don Gardener even read this piece, much less paid for it?