FBI thinks it wants to get involved with agroterrorism!

Agroterrorism is a term coined since 9/11 to denote the deliberate introduction of disease causing organisms and
chemicals into the food supply through agriculture. This is a term that adequately describes the municipal disposal of
disease causing organisms and toxic chemical laden sewage sludge on agricultural land, as well as forests, parks and
home lawns and gardens. The sewage sludge industry coined the term Biosolids to denote sewage sludge disposed of
as an agricultural fertilizer or residential soil amendment that could be too contaminated with inorganic chemicals to be
disposed of in a regulated surface disposal site, where crops could also be grown.

While disease organisms are an immediate threat, chemicals and disease organisms are also a long term threat that
doesn’t show up on the agro terrorism radar.
    "Among U.S. residents, 1 in 2 men and 1 in 3 women will develop cancer at some point in their lifetimes. .
    Research shows that environmental factors trigger diseases like cancer, especially when someone has a family
    history," said Kenneth Olden, Ph.D., director of the National Institute of Environmental Health Sciences and the
    National Toxicology Program, which prepared the report for HHS.”

    “The Department of Health and Human Services released its Eleventh Edition of the Report on Carcinogens today
    [Jan 31, 2005], adding seventeen substances to the growing list of cancer-causing agents, bringing the total to
    246. For the first time ever, viruses are listed in the report: hepatitis B virus, hepatitis C virus, and some human
    papillomaviruses that cause common sexually transmitted diseases. Other new listings include lead and lead
    compounds, X-rays, compounds found in grilled meats, and a host of substances used in textile dyes, paints and

The Federal Bureau of Investigation (FBI) and Joint Terrorism Task Force (JTTF) have taken an proactive interest in
preventing agroterrorism  based on the Congressional Research Service (CRS) report to Congress (February 2005).
The report states, “The potential of terrorist attacks against agricultural targets (agroterrorism) is increasingly
recognized as a national security threat, especially after the events of September 11, 2001. Agroterrorism is a subset of
bioterrorism, and is defined as the deliberate introduction of an animal or plant disease with the goal of generating fear,
causing economic losses, and/or undermining stability. Attacks against agriculture are not new, and have been
conducted or considered by both nation-states and substate organizations throughout history.”

Furthermore, “The results of an agroterrorist attack may include major economic crises in the agricultural and food
industries, loss of confidence in government, and possibly human casualties. Humans could be at risk in terms of food
safety or public health, especially if the chosen disease is transmissible to humans (zoonotic). Public opinion
may be particularly sensitive to a deliberate outbreak of disease affecting the food supply. Public confidence in
government could be eroded if authorities appear unable to prevent such an attack or to protect the population’s food

According to government documents between 1986 and 1997 food poisoning incidents exploded from 1-2 million cases
a year to 81 million cases year after EPA started promoting the disease causing organism and chemical laden sewage
sludge as a fertilizer for food crops. It was, and is, EPA’s contention that sewage sludge/biosolids containing the most
probable number of two billion fecal coliform bacteria per kilogram makes a wonderful food crop fertilizer if a farmer waits
30 days before harvesting the food crop. The most wonderful sewage sludge/biosolids, which is even safe for babies to
crawl around the yard only contain the most probable number of one million fecal coliform bacteria per kilogram. No one
tells the farmer or the mother that the spore forming and vegetable cell bacteria may be viable, but non-cultureable by
standard laboratory methods.

The CRS report notes only one of the many toxins produced by the spore forming bacteria Clostridium perfringens, -
epsilon toxin - (a potential biological warfare agent) is addressed in the bioterrorism regulation. Other human disease
causing agents listed are, Botulinum neurotoxin-producing species of Clostridium, Staphylococcal enterotoxins, (Valley
fever) Coccidioides immitis and Shigatoxin, commonly produced by bacteria Shigella dysenteriae and enterhemorrhagic
Escherichia coli. Staphylococcal (which causes Toxic Shock Syndrome), in combination with Clostridium perfringens
(which causes gas gangrene), will cause
Necrotizing fasciitis, commonly referred to by the media as flesh eating

According to Susan McGinley, UA, College of Agriculture, “C. perfringens related livestock infections have been
reported in every state in the nation and in most parts of the world. Although surgery can save human victims, it is often
not feasible to perform it on domestic animals.”

The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (Pub. L. 107-188), provides for
the regulation of certain biological agents
1 and toxins 2 that have the potential to pose a severe threat to public health
and safety, to animal health, to plant health, or to animal and plant products.
1 Any microorganism (including, but not limited to, bacteria, viruses, fungi, rickettsiae, or protozoa),
or infectious substance, or any naturally occurring, bioengineered, or synthesized component of any
such microorganism or infectious substance, capable of causing:
  • (1) Death, disease or other biological malfunction in a human, an animal, a plant, or another living organism;
  • (2) deterioration of food, water, equipment, supplies, or material of any kind; or
  • (3) deleterious alteration of the environment.

All of these disease organisms, and more, have been routinely spread on agricultural land and forests for the past 25
years as well as on home lawns and gardens under an EPA policy. EPA has formalized the policy in February 1993 as
the self-permitting part 503 sludge use and disposal regulation. In 1995 EPA removed chromium at 3,000 ppm from the
Use Section when it was pointed out that the Disposal Section only allowed 600 ppm.

In 1999, biosolids got much more dangerous according to the Federal Register: “EPA is today [August 4, 1999]
establishing the total chromium concentration in
Appendix G--Section II for land-applied sewage sludge at
100,000 mg/kg.” The same level allowed for lined disposal sites. The allowable concentration for Cancer causing
(by inhalation) hexavalent chromium is 12,000 mg/kg, which can not be disposed of in a
Surface Disposal site that
limits chromium to 600 ppm 150 meters from the site boundary.

As an
underlying hazardous constituent, chromium must be treated to below the 0.6 mg/L universal treatment
standard for the waste to be properly land disposed (58 FR 29560, May 24, 1993 and 63 FR 28556, May 26, 1998).

Under EPA’s Emergency Response Program, it recognizes that,
    “The variety of hazardous substances used in our everyday lives brings with them an equally great variety of well-
    documented health effects. In some cases, these substances may irritate the skin or eyes, make it difficult to
    breathe, cause headaches and nausea, or result in other types of illness. Some hazardous substances may
    cause far more severe health effects, including behavioral abnormalities, cancer, genetic mutations, physiological
    malfunctions (e.g., reproductive impairment, kidney failure, etc.), physical deformations, and birth defects. A close
    look at the list of sources of common contaminants and their health effects illustrates just how prevalent they are
    in our society, and how damaging they can potentially be.”

    “Impacts on the environment can be just as devastating: hazardous substances can kill living organisms in a lake
    or river, destroy wildlife and vegetation in a contaminated area, cause major reproductive complications in wildlife,
    or otherwise limit the ability of an ecosystem to survive. Certain hazardous substances also have the potential to
    explode or cause a fire, threatening both wildlife and human populations.”

    “Some hazardous substances produce toxic effects in humans or the environment after a single, episodic release.
    These toxic effects are referred to as the acute toxicity of a hazardous substance. Other hazardous substances
    produce toxic effects in humans or the environment after prolonged exposure to the substance, which is called
    chronic toxicity.”

Part 503.9(t) uses the term pollutant to describe the same exposure effects from sludge/biosolids through air, water or
food chain.
CWA uses the term Toxic pollutant while RCRA hazardous waste rules use the term Hazardous Constituents

The closer municipalities can get these extremely hazardous and toxic pollutants to the public, the less rules are
required: "When sewage sludge is not used to condition the soil or to fertilize crops or vegetation grown on the land, the
sewage sludge is not being land applied. It is been disposed of on the land. In that case, the requirements in the subpart
on surface disposal in the final part 503 must be met." (FR. 58, 32, p. 9330)

This information is not given to the farmer or home owner who may purchase unlabeled sludge/biosolids so they can
make an informed choice. According to EPA’s Doctor of Philosophy, Alan Rubin, who claims to have been the lead
author of part 503, “Their concerns about biosolids land application are many. Their main and overt concern about this
practice is "safety" and their perception of negative human health and environmental impacts. Based on my experience
at EPA and my expertise, this concern is not valid”

However, EPA's Robert Bastian admits, "Concerns raised over emerging pathogens and chemicals for which little or no
data are available tend to be put off for future consideration when more adequate data are generated.

A perfect example of this dangerous municipal policy of misleading the public by claiming sludge is a nutrient-rich
organic fertilizer was noted in the Kansas City Star , August 03, 2006,
One county's waste is another's fertilizer
It is understood that Johnson County, Kansas wastewater administrator John O’Neil would not have quit sending sludge
to the landfill under part 258 as required by federal law without EPA pressure to remove sludge from municipal solid
waste (MSW) landfills, to prevent adding to the 250 MSW Superfund sites

Good Federal Laws have been enacted to protect human health and agriculture as well as the environment from
exposure to spreading of disease causing organisms and chemicals. Unfortunately,
EPA and USDA policy promote the
uncontrolled spreading of disease causing organisms and chemicals in the environment.

While the Federal Bureau of Investigation (FBI) and Joint Terrorism Task Force (JTTF) are taking a proactive approach
trying to prevent human and environmental damage from the spreading of disease causing organisms and chemicals by
terrorist, how can they tell the difference between a terrorist act and the normal business act of a municipality.

May 3, 2005 INTERNATIONAL SYMPOSIUM ON AGROTERRORISM (ISA) sponsored by the FBI and JTTF identified
the following Conference Goals: To prevent an act of Agroterrorism in the U.S. through a well coordinated intelligence
collection, analysis and dissemination process: to develop a technical and tactical response capability sufficient to
neutralize and eliminate a potential attack: and to educate the agriculture community on the role of law enforcement in
responding to threats directed at the nation's food supply.

During the 18 August 2005 Agroterrorism Assembly in Sacramento, California, US Department of Homeland Security
and the University of California's Western Institute for Food Safety & Security, The presentations showed that
agroterrorism must be everyone’s concern because of its potential to cause;
1. massive illnesses and deaths,
2. serious disruption to food supply,
3. economic disruption and
4. loss of confidence in government and industry.

The Conference Goal of the 2006 International Symposium on Agroterrorism (ISA) to be held September 25 through 29,
2006 at the Westin Crown Center, Kansas City, Missouri: will build upon the information that was presented at the initial
symposium, devoting increased time and attention to specific topics related to the prevention, detection and
investigation of an intentional attack against the food supply.

Since municipalities, state and federal agencies have refused to investigate any deaths or health complaints caused
by disease organisms and chemicals being spread on agricultural land the FBI and JTTF are not going to accomplish
their mission of protecting agriculture and public health. This is going to further erode public confidence in government.

The question that should be addressed since we were in a cold war at the time: Was the original decision to remove
sludge from the federal laws, under a policy, by an
individual at EPA done as an intentional attack against the food
supply of the United States as well as its public health?