Deadly deceit is the only name that can be given to the EPA's 25
year old policy of promoting the disposal of hazardous sewage
sludge as a fertilizer on farmland, home lawns and gardens, golf
courses, parks, athletic fields, school grounds, and forest.

This site is dedicated to the truth behind the EPA's sludge policy
and the lack of science associated with it. In 40 CFR 503.9(t), EPA
warns that exposure to any of the pollutants in sludge (metals,
disease causing organisms, inorganic compounds, organic
compounds, etc) through the air, water, or food, will cause death,
disease, cancer and other physical and mental health effects.
Yet, EPA claims that there is 30 years of science which proves
that hazardous sewage sludge is safe to use as an unlabeled

Over the past 15 years, farms have been destroyed as a result of
EPA's promoting hazardous sewage sludge as a safe fertilizer.
Lives have been destroyed as a result of EPA's promoting
hazardous sewage sludge as a safe fertilizer.
Deaths have

Over the past thirteen years,
numerous organizations across the
country have been organized to
stop or ban the disposal of
hazardous sewage sludge.
These organizations have documented
hundreds of cases of human, animal health as well as
environmental damage. Many have succeed in getting hazardous  
Sewage sludge disposal as a fertilizer banned,
one county at a

To counteract the activities of these organizations, EPA created a
federal sludge use and disposal regulation based on its policy,
rather than any of the Environmental laws created by Congress.
EPA then put two of its scientists out front to lead a multi-million
dollar public relations campaign to change the publics as well as
states' legislators perception, about the dangerous nature of
hazardous sludge used as a fertilizer.  One result is that now the
most dangerous sludge is called "Biosolids" and marketed as an
unlabeled fertilizer.

EPA's multi-million dollar public relations campaign convinced
many states that it would be responsible for enforcing the  
regulation. However, many
state's revised the solid waste laws to
comply with EPA's policy. Today, some of the same states have
assumed liability for EPA's hazardous sludge disposal policy as a
means to prevent counties from banning sludge use as a fertilizer.
In 1995, Chromium was removed from the part 503 land application
section. John Walker claimed the court ordered EPA to remove chromium
from the 503.

EPA actually  told the court it had no creditable research on chromium.
Just a few pot studies in which it had no confidence. The court remanded
EPA to do the research.

Chromium at 3,000 ppm  was at an extremely hazardous levels.
hazardous waste division will only allow 21.3 ppm for fertilizer with 35.5%
zinc content, for its recycled hazardous waste fertilizer, 67 Fed. Reg. at

,But It is really all about (money)  removal credits for the polluters.
Federal Register: October 25, 1995 (Volume 60, Number 206)]
[Rules and Regulations ]               
[Page 54763-54770]

SUMMARY: On November 25, 1992, pursuant to Section 405 of the Clean
Water Act (CWA), EPA promulgated a regulation (40 CFR part 503) to
protect public health and the environment from reasonably anticipated
adverse effects of
certain pollutants in sewage sludge (58 FR 9248,
February 19, 1993). This regulation established requirements for the
final use or disposal of sewage sludge when: (1) The sewage sludge is
applied to the land either to condition the soil or to fertilize crops
grown in the soil; (2) the sewage sludge is placed on the land for
final disposal; or (3) the sewage sludge is incinerated. In addition,
EPA also amended the General Pretreatment Regulations (40 CFR part 403)
to establish a
list of pollutants for which a removal credit may be
Today's action amends the part 503 sewage sludge regulation as a
result of EPA's reconsideration of certain issues remanded by the U.S.
Court of Appeals for additional justification or modification. The
Agency is deleting the current land application pollutant limits for
chromium and changing the land application pollutant concentration
limit for selenium.
EPA is also amending the list of pollutants for which a removal
credit may be available. This final rule removes chromium in sewage
sludge that is land-applied from the list of regulated pollutants for
which a removal credit may be available and adds it to the list of
unregulated pollutants that are eligible for a removal credit.

EFFECTIVE DATE: The final rule is effective October 25, 1995. For
purposes of judicial review, the final rule is issued at 1 p.m. on
October 25, 1995.
October 16,  Letter to the Editor of EPA's in-house magazine about
Administrator Ruckelshaus' re-writing history.  EPA had taken a lot of
heat (which I helped generate) about it's failure to implement the
hazardous waste regulations under RCRA, so they invented the
excuse that nobody in EPA knew anything about hazardous waste until
a half hour ago.  This fairy tale re-appears many times in different
guises.  Posted 4/9/99

As early as 1977 EPA's William Sanjour was writing letters against the use of
sludge as a fertilizer for food crops.
 William Sanjour
                                                                 2445 Lyttonsville Road
                                                            Silver Spring, Maryland 20910

                                                                    October 25, 1977

Dear Editor,

I don't understand the logic of your editorial of October 22 implying the use of sewage sludge from
heavily industrialized cities such as Milwaukee may be safe for use as a fertilizer in farming and
gardening. Half of the input to such sewer systems is the wastes from industrial sources such as
chemical plants and metal plating shops. The resultant sewage sludge from Milwaukee and other
industrial cities is laced with poisonous chemicals, including cadmium and PCBs. In short, the
municipal sewage plants in industrial. cities are essentially one big industrial waste water treatment

As a result of Federal clean water laws, those industries have taken more and more to dumping their
waste in the sewer, rather than directly in the streams, thereby transferring the problem to the
municipalities. The municipalities have encouraged this practice because it defrays the cost of the
municipal treatment plants. I'm sure the Washington Post would never dream of running an editorial
advocating the use of toxic industrial and chemical wastes as fertilizer, yet passing these wastes
through a. municipal sewage treatment plant (largely paid for by industry) and stamping the resultant
waste as "Milorganite" or "Nu-Earth" somehow makes it alright.

The simple question which some "environmentalists"seem unwilling to face head-on is that if those
wastes are so dangerous that they cannot be dumped in the oceans or the rivers for fear of the effects
on the life in those environments, how come they are advocating injecting them directly. into our food?

Sincerely yours,
William Sanjour
Deadly Deceit
Hazardous Sewage Sludge
Science - Politics - Law
EPA claims there are no peer
reviewed published papers which
show that sludge is harmful to
humans are animals.

Not True!
EPA claims part 503
sludge/biosolids is  not a hazardous

EPA claims that Chromium was
removed from part 503 policy
guidelines by order of Federal Court.

Not True!
EPA claims the sludge rule is

Not True
EPA claims there was a risk

Not True
EPA claims that pathogens die off
within 30 days

 Not True
EPA claims there are no health
hazards with sludge used as a

 Not True
EPA claims there is no problems
with sludge use.

Nation Association of Counties says

Not True
Testimony of
EPA's David L. Lewis
Attorney Ed Hallman's
Testimony to Congress
in support of Lewis