EPA and the states' intent has been to get rid of upward of 10 million tons of very
hazardous sludge with the least possible paperwork and cost. Death, disease and
cancer visited on the general public are simply collateral damage. Governments are
amoral and the collateral damage is just one of the cost of doing business the public
has to pay.  Why else would EPA try to hide information on five of the twenty-one
carcinogens in sludge which are carcinogenic when inhaled in dust --  Arsenic,
Beryllium, Cadmium, Chromium IV and Nickel? (Federal Register  54, p. 5777).

Why would EPA consider that these five deadly pollutants will not cause cancer when
disposed of in unlabeled Class A compost fertilizer? What magic would prevent your
exposure when you buy an unlabeled bag of this deadly killer?
In Canada, the government recognizes that exposure to dried sludge will cause the
respiratory disease "extrinsic allergic alveolitis". It is called:
Sewage sludge disease
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 and sewage sludge was a very
dangerous occupational risk.
To justify their contention that sludge is safe, proponents of beneficial use of sludge claim no
workers in treatment plants have suffered ill effects from working there. However, several
scientific studies of treatment workers in the United States and Europe dispute this claim.
Researcher J. R. Nethercott in his article "Airborne Irritant Contact Dermatitis due to Sewage
"Sludge", in the Journal of Occupational Medicine, November 1981, 23, (11) p. 771-4 reported
how an airborne irritant in sewage sludge caused an outbreak of cases of dermatitis among
incinerator workers employed in a sewage treatment facility. The cause of the problem was
traced to contamination of the workplace and workers' clothing by sludge from the interstices
of an incinerator exhaust fan.  Tests on rabbits confirmed the irritancy of the sludge.

Scientists Kraut, Lilis, Marcus, Valciukas, Wolff, and Landigan of the Department of Community
Medicine, Mount Sinai School of Medicine, New York City, New York reported their findings on
solvent toxicity to workers in sewage treatment plants in the article "Neurotoxic Effects of
Solvent Exposure on Sewage Treatment Workers" in the Archives of Environmental Health,
July/August, 1988, 43, (4), pp. 263-68. They found after examining nineteen STWs (Sewage
Treatment Workers) exposed to industrial sewage that contained benzene, toluene, and other
organic solvents at a primary sewage treatment plant in New York City (Plant A).  that fourteen
(74%) complained of central nervous system (CNS) symptoms consistent with solvent
exposure, including lightheadedness, fatigue, increased sleep requirement, and headache.
The majority of the symptoms resolved when the workers were transferred from the plant. The
researchers found objective abnormalities in neurobehavioral testing in all four men who had
worked longer than 9 years at the plant but in only 5 of 15 employed there for a shorter period
of time. They concluded that these results are consistent with the known
effects of solvent exposure.

Another study of the health of employees at six sewage treatment plants and three drinking
water plants (control) performed in England by scientific researchers Lundholm and Rylander,
reported in an article entitled "Work Related Symptoms Among Sewage Workers" in the British
Journal of Industrial Medicine in August 1983, revealed that a higher proportion of employees
at sewage treatment plants reported skin disorders, diarrhea, and other gastrointestinal
symptoms than the control group.  In order to characterize exposure to aerosols of sewage
water, serum immunoglobulin concentrations, white blood cell counts and fibrinogen
degradation product concentrations (FDP) in urine were determined by the researchers as
were the number and species of airborne Gram negative rods. The researchers found no
significant differences between the groups for white blood cell count or serum immunoglobulin
concentrations except that IgM concentrations were slightly higher in the sewage workers.  
Some workers had serum transaminase concentrations in excess of normal and among
non-smokers a higher proportion of sewage treatment workers had increased amounts of FDP
in urine.  Their conclusion was that it was conceivable that the cause of the symptoms was
from toxins from Gram negative bacteria.

The results of a clinical investigation that was made among workers in a sewage treatment
plant in Switzerland with similar aged workers in a control group who were not exposed to
sewage showed that in about half of the exposed workers there were acute incidences of fever
and eye symptoms.  Serum immunoglobulins, white blood cells and thrombocytes were
elevated in the exposed workers and a higher percentage of increased levels of C-reactive
protein and fibrinogen degradation products were found in the exposed group compared to the
control group. The investigation did not establish a definite cause-effect of endotoxins but they
were suspect. Endotoxins are poisonous substances present when bacteria die. (Rylander, R.,
Andersson, K., Belin, L., Berglund, G., Bergstrom, R., Hanson, L., Lundholm, m., and Mattsby,
I, Studies on Humans Exposed to Airborne Sewage "Sludge", Journal Article with English
abstract, Schweiz Med Wochenschr, February 12, 1977, 107 (6), pp. 182-4).

When scientific researchers Clark, Bjornson, Fulton-Schwartz, et al from the University of
Cincinnati Medical Center, Cincinnati, Ohio, conducted an epidemiological study of the health
of compost workers which they reported in the article "Biological Health Risks Associated with
the Composting of Wastewater" in Journal of Water Pollution Control Federation, 1984. 57
(12), pp. 1269-76, they found there were biological effects on the workers from their exposure
to composts. {Composting is the waste disposal process which allows waste to decompose or
rot). The study included a clinical and serological evaluation of workers who were exposed with
workers who were not exposed (control group).  Physical examinations of the control group
revealed there was an excess of abnormal eye, ear, nose and skin conditions among the
workers exposed to the composts.  Nose and throat cultures were positive for Aspergillus
fumigatus.  These examinations also showed antibody to endotoxins in compost was
sometimes higher among compost workers than others and there was a low-grade
inflammatory response in some of the
compost workers.

Composting causes serious health related problems for compost workers including an excess
of nasal, ear, and skin infections, burning eyes and skin irritation, increased fungal colonies,
and higher white blood cell counts and hemolytic complement (A letter to Kenneth Olden of
NIEHS from Drs. Jordan A. Fink, Professor of Medicine, Chief Allergy Immuno Therapy Division,
Medical College of Wisconsin,November 3, 1992)

It has been recognized in Germany, at least since D. Strauch published a paper in 1991, 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."

Some pathogens have even developed resistance to time-tested controls such as heat and
refrigeration. Several of the alternatives to reduce pathogens in sludge products use
heat at temperatures of 55 C and above to achieve Class A status. However, according to the
article "Pathogen Destruction and Biosolids Composting" in Biocycle of June of 1996, "There is
some evidence that coliforms and Salmonella sp. can survive prolonged exposure to
temperatures of 55 C."

They cite a study done by Droffner and Brinton (1995) using DNA gene probes, where they
detected E. coli and Salmonella sp. in samples collected from an in-vessel composting facility
after the first 15 days of active composting at a temperature above 55 C. In Table 5-4
Processes to Further Reduce Pathogens in A Plain English Guide to the EPA Part 503
Biosolids Rule, composting time and temperature requirements for within-vessel composting
method was 55 C or higher for three days!  Droffner and Brinton found that it took 56 days and
90 days for the densities of Salmonella sp. and E. Coli, respectively, to decline below the
detection limit...These investigators also "cite evidence of mutant strains of E. coli and
Salmonella sp. resistant to thermal environments in composting." (p. 68)

According to microbiologists, some bacteria form an endospore, a cell type developed from the
vegetative bacterial cell through a sequence of morphological changes. Although the
vegetative cell of bacteria is usually killed by heat and disinfectant, the endospore is resistant
to agents that kill the vegetative cell (heating, drying, freezing, chemicals, and radiation).  
Nester, Roberts, Pearsall and McCarthy (1978) in their text Microbiology point out the threat
that endospores present.  They say:

Endospores represent the most resistant form of life
known; they tolerate extremes of heat and dryness, the
presence of disinfectants, and radiation. Some members
of Bacillus and Clostridium play a role in fixing
atmospheric nitrogen and others cause serious infectious
diseases. Thermophilic strains of Bacillus can grow at
temperatures above 70 C (158 F) (p. 260)

Linne and Ringsrud (1979) in their text Basic Techniques for the Medical Laboratory also point
out how spores, as highly resistant forms of bacteria, pose a great problem in sterilization.
They state that certain spores have been known to survive 16 hours of boiling. (p. 452)