It Doesn't Work

By Jim Bynum
Retired Safety Consultant

A High-Level Disinfection Standard for Land-Applied

Lewis was a highly respected microbiologist at EPA.  Once he exposed the lies
supporting sewage effluent recycling, EPA and the waste industry have brought
discredit upon his name as an expert witness in the legal system. I know. It is in the
public records,  I had to write Lewis a letter to that effect when I desperately required
his expert testimony in court.  Lewis mentioned the high levels of E. coli I required
expert testimony for in
Sludge Magic at the EPA, The Journal of Commerce; January
27, 1999. Today, Lewis can not even comment on a sludge issue because of pending
court action.

You will notice the disinfection levels discussed in this study are achieved in a
medical laboratory -- not in a wastewater treatment plant.

EPA acknowledges that low levels of disinfection will injure coliforms.  EPA stated in 1989,
"Because total coliforms are common inhabitants of ambient water and
may be injured by
environmental stresses (e.g., lack of nutrients) and water treatment (e.g., chlorine disinfection)
in a manner similar to most bacterial pathogens and many viral enteric pathogens,
considers them a useful indicator of these pathogens."
It is useful to hide the exposure
danger, in effect the injured bacteria become viable, but nonculturable by standard
laboratory methods. There is one more problem.  "
Unlike other E. coli, isolates of
serotype O157:H7 do not ferment D-sorbitol within 24 h, lack-glucuronidase activity,
and do not grow at 45.5°C"  

Current federal standards for pathogen reduction in sewage sludge are based on levels of
indicator organisms, such as Escherichia coli and Salmonella.
[fecal and coliform bacteria]

Because all federal  and state requirements are based on less resistant indicator organisms, it
is not known whether current methods, including aerobic and anaerobic digestion, heat
treatment, lime stabilization, and composting, could achieve high-level disinfection.

Table 1. Disinfection levels required to kill pathogens in sewage sludges.(a)
Group Disinfection                                                                                            level required
Bacterial endospores (e.g., Bacillus anthracis)                                                 
Nonenveloped viruses (e.g., Norovirus, Coxsackie, Rotavirus)                        
Helminths (e.g., Ascaris, Toxocara)                                                                   
Protozoa (e.g., Cryptosporidium, Giardia)                                                         
Mycobacteria (e.g., M. tuberculosis)                                                                  
Fungi (e.g., Candida)                                                                                         
Vegetative bacteria (e.g., Staphylococcus, Salmonella)  
Enveloped viruses (e.g., hepatitis B, HIV, influenza)                                           
Data from the Association for the Advancement of Medical Instrumentation (AAMI 1994).
(a) Disinfection levels are based on susceptibilities to liquid chemical germicides; groups increase
similarly in resistance to heat, with enveloped viruses being the most sensitive and bacterial endospores
the most resistant

Most bacteria found in sewage sludge produce either endotoxins or exotoxins, both of which
can cause severe illness or death. As sludges decompose, toxins can leach into groundwater,
enter surface water runoff, and be carried away in airborne dusts. Considering that tons of
decomposing sewage sludge per acre are often applied to hundreds or thousands of acres
many times a year, land-application sites have a potential for producing and exporting large
quantities of toxins.

Unlike most exotoxins, endotoxins are heat stable even upon autoclaving (Baines 2000). They
can, however, be inactivated with dry heat at > 200oC for 1 hr (Williams 2001). Traces of
endotoxins in food and water can cause headaches, fever, fatigue, and severe gastrointestinal
symptoms; however, their primary target is the lungs. In addition to the former symptoms,
inhaling endotoxin-contaminated dusts can cause acute airflow obstruction, shock, and even
death. Chronic respiratory effects can also develop [American Conference of Government
Industrial Hygienists (ACGIH) 1999].

Nearby residents exposed to dusts from land-application sites report many of the same
symptoms of endotoxin poisoning that have been documented among sewage treatment plant
workers. These include flu-like symptoms, nausea, vomiting, diarrhea, headaches, and difficulty
breathing (Lewis et al. 2002). Rylander (1987) proposed occupational exposure limits
to endotoxin-contaminated cotton dusts. Based on average air concentrations over an
8- to 10-hr workday, he suggested limits ranging from 200 EU/m3 to prevent airway
inflammation to 20,000 EU/m3 to avoid toxic pneumonitis. The exposure levels of
endotoxin-contaminated aerosols with sewage treatment plant workers have ranged from
80 to 4,100 EU/m3 (Liesvuori et al. 1994). The toxins, however, have a greater effect on
people with immune systems compromised by injury or illness (Baines 2000).

Detection of Pathogens  (1998)
Deadly Deceit    CHAPTER 7,   Deadly Microbes

D. Strauch in his 1991 paper, "Survial of pathogenic  micro-organisms and parasite in
extreta, manure and sewage  sludge" reported that two groups of researchers had
found  that pathogenic disease organisms will be taken up inside the  food crops.  In
other words, it will do little good to wash  the outside of fresh vegetables and fruit
when the pathogenic  bacteria, viruses and worms from the sludge can be inside the  
plant.  Strauch concluded in his report that, "In any case,  the agricultural utilization of
hygienically dubious sewage  sludge poses a risk for the whole national economy."

It has been recognized in Germany, at least since D. Strauch published his 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."

In a personal interview with scientist David Lewis of the EPA, who is a whistleblower, more
disturbing facts about pathogens and their detection came to light including the information
about the AIDs virus. According to Lewis, standard test methods underestimate the number of
water repellant contaminates. In looking at the aids virus found on medical and dental tools,
Lewis discovered that the HIV virus, when it was covered with a water repellant lubricant such as
silicone, was still infectious after several days.

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. "Body
fluids also break down the lubricants surrounding the contaminates," he said.

Lewis has brought these facts to the attention of the Food and Drug Administration who is
supposed to be setting up a committee to study the problem.

"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 revealed. In effect, it appears
that the treatment processes hide most of the pathogens rather than destroying them.

Straub, Pepper and Gerba say that the list of pathogens are not constant but keep changing:
As advances in analytical techniques and changes in society have occurred, new pathogens
are recognized and the significance of well-known ones change.

Microorganisms are subject to mutation and evolution, allowing for adaptation to changes in the
environment. In addition, many pathogens are viable but nonculturable by current techniques
(Rozak and Colwell 1987), and actual concentrations in sludge are probably underestimated.(p.

They add further: Thus, no assessment of the risks associated with the land application of
sewage sludge can ever be considered complete when dealing with microorganisms. As new
agents are discovered and a greater understanding of their ecology is developed, we must be
willing to reevaluate previous assumptions. (p.  58).

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
evidence of mutant strains of E. coli and Salmonella sp. resistant to thermal
environments in  composting." (p. 68)