In the Augusta, Ga. cases, we have found  extremely  high levels of chlordane, which is outlawed for
land application and virtually any purpose, cadmium, mercury and chromium, among others. Augusta
provided a wonderful opportunity for the EPA and the state environmental agency to come down hard
on a very bad actor. The fact that they did not do so shows how corrupt the sludge industry and the
agencies are on the subject.

Attorney Ed Hallman's written testimony to congress concerning EPA's sludge rule Full text @

It would appear that the highly intelligent, highly educated people at EPA would know that the so called
regulated levels of inorganic and organic chemicals which determine a hazardous waste have nothing
to do with how dangerous the chemicals are to human and animal health. Do you really think these
highly educated people failed to find out that the regulated level of a chemical is only that level which is
expected to leach out of a mismanaged landfill and contaminate the groundwater under the site above
the level established for drinking water?

EPA' Office of Water has claimed that its 1993 Sludge Use and Disposal policy regulation 40 CFR 503
was created under the Clean Water Act (CWA). Yet, EPA failed to comply with the basic Congressional
Order of the CWA to identify the toxic pollutants in sludge. Not only that, but EPA failed to even
acknowledge that there are any toxic pollutants in sludge in the 1993 final part 503 sludge policy.

Hazardous substance

Both treated and control animals exhibited signs of discomfort immediately after dosing. These signs
were manifest as frequent examinations of the injection site and increased activity. However, fifteen to
thirty minutes after dosing, the Boston sludge-treated animals began to show signs of effects on the
central nervous system.

Lucas reviewed the nonmicrobiologic contaminates of wastewater aersols, noting that toxic gases and
myriad chemicals, both organic and inorganic, may pose a significant hazard to wastewater treatment
workers and potentially to thegeneral public in surrounding areas

health effects from hazardous sewage sludge and effluent


Class B; Sewage Sludge contains harmful Bacteria, Enteric Viruses, Protozoa and Parasites. Exposure
to these organisms may cause severe adverse health effects, including typhoid fever, dysentery,
gastroenteritis, diarrhea, abdominal pain, cholera, hepatitis, meningitis, pneumonia, paralysis,
encephalitis, respiratory problems and fever.

The only problem with this new EPA research on prions in sewage sludge biosolids is that it fails to
consider HUMAN as well as animal prions in BOTH CLASS A and CLASS B sewage sludge . . . . . Class
A sewage sludge biosolids compost ;fertilizer (such as Milorganite) which may contain both infectious
human and animal prions is sold by the bag to an unsuspecting public at WalMart, Home Depot,
nurseries, hardware stores, etc. it is spread on ballfields, playgrounds, and homeowners are
encouraged to spread it on their lawns and in their flower and vegetable gardens . . . . kids eat dirt --
and  kids eat LOTS of dirt ! And obviously, topdressing prion infected Class B sewage sludge on
grazing lands and dairy pastures puts both livestock and cervids at risk of ingesting infectious prions .


Heterotrophic bacteria. What expert said they are not disease causing pathogens?.

The sludge war of Kern County, California has united Democrats and Republicans in an effort to stop
the spreading of deadly chemical and biological agents on county farmland. A new weapon was added
to the political arsenal on July 1st, when Kevin McCarthy, the state Assembly Republican leader and
other political leaders filed a local ballot initiative to ban the use of chemical and biological
contaminated sewage sludge as a safe  fertilizer on farmland.

According to the NRC report, sludge dumping has a longhistory. Sewage farms were first established
about 150 years ago and the agricultural benefits were incidental.The farms were phased out as the
land area required to dispose of large cities grew to great to be practical and effective technologies
were developed to treats ewage. In fact, according to the NRC report, These technologies eliminated
the need for sewage farms.

This revolution in waste disposal was born of an era of pink antibacterial hand soap, treacly air
freshener and increasing scrutiny at the other end of the pipes. The Environmental Protection Agency
has argued that spreading sludge on farmland is safer than old methods of disposing of it in rivers and
oceans. Synagro agrees, and pledges in its mission statement to enhance the environment and the
quality of the communities that we serve.

Death will result for a relatively few people (5,000 to 9,000) each year from Enteric fever, Meningitis
(inflammation of the membrane of brain and spinal cord), Carotids (inflammation of the heart), Central
nervous system involvement (brain and spinal cord), Pneumonia, infectious hepatitis, severe (acute)
respiratory infections (lungs), Cholera, hookworm, tapeworm, Visceral larva, migraine, Ascariasis,
Taeniasis, Toxoplasmosis, Balantidiasis, Amebic dysentery, Giadiasis, Aspergillosis, (FR 54-p.5829).

if your family has experienced life threatening liver, lung, heart, or brain illnesses, cancer, death or
even birth defects, you may have been touched by the plagues that have been released upon our
lands by the same three federal agencies, USDA, HHS, and EPA,

First of all, I assume you are being coy in not mentioning the ongoing EPA funded research by Trina
McMahon, et al, UW-Madison re prions in sewage sludge.
( problem with the UW-Madison research and your
email  is that both ignore the significant issue of human prions being discharged to public sewers, which
are reconcentrated by the wastewater treatment process in BOTH Class A and Class B sewage sludge
biosolids (hereinafter called sludge).

Municipal sewage sludge poses a measurable neurotoxic hazard to nearby residents and farm workers,
who need to be informed of possible neurotoxic injury from their exposure, and then monitored using
repeated neurobehavioral tests. Based on medical evaluation, immunological tests and lung biopsy
organic toxic dust syndrome and pulmonary fribosis were diagnosed in this
young compost worker. He was medically removed and a worker's compensation claim is pending

Index --
Antibiotic Resistants -- Genetic transfer of toxin producing genes between bacteria.
Index -- Hazardous
Bacteria  in sludge biosolids and reclaimed water into food & drinking water
Index --
Food Poisoning from hazardous substances in sludge biosolids, reclaimed and drinking water
Index -- Hazardous
Fungus in sludge biosolids and compost
Index --
Pandemic diseases in the United States 1980 - 2007
Index -- Public
health effects from hazardous sewage sludge and effluent
Index -- Hazardous
Viruses in sludge biosolids and reclaimed water into food and drinking water
Index --
Viable, but nonculturable disease organisms in sewage sludge and effluent.

The NAS Committee based their premise that sludge was safe for use on crops on the assumption that:
(1)the EPA's risk assessment was accurate, (2) the federal regulations were the laws, (3) the regulated
procedures would be followed to the letter, (4) the treatment process and equipment would consistently
produce the same quality of sludge, (5) there were no scientifically documented outbreaks of infectious
diseases from the useof sludge on crops.

Jane Biswick
Sludge testimony before Congress, 2000

Don't laugh, but the first draft of Kern's sludge ban has an almost revolutionary ring to it: In order to
promote the general health, safety and welfare of Kern County and its inhabitants ... the land
application of Biosolids shall be prohibited in the unincorporated area of Kern County. Supervisors
headed straight into the jaws of a formidable beast Tuesday, setting sights on a total sludge ban here.

Am I nuts, or something? I see this as a huge victory for Kern County -- and localities around the
country who have been hauled into court for enacting local sludge control ordinances . . . . . . this
decision clearly iterates Congress' intent that there be local control -- and that local ordinances do not
violate the commerce clause . . . . . furthermore, I have been arguing for years with EPA types (Walker,
Rubin, Bastian) that local determination  - means what it says . . . they have been insisting for years
that I am wrong and that it refers only to the right of the POTW/generator to determine the manner of
disposal . . . . and not to any rights of the receiving community . . . . I have already shot off the portion
of the decision resolving this issue to my EPA ;good buddies;

BAKERSFIELD -- Keep Kern Clean, the campaign to fight dumping of Southern California's sewage
sludge on Kern County fields, today will file a proposed initiative to ban the practice.Gene Lundquist, a
member of the Kern County Water Agency board who has publicly expressed his concerns about land
application of sludge above the groundwater table, will present the committee's notice of intent to
circulate petitions at 3:00 p.m. to the county elections office.Senator Dean Florez, D-Shafter, has been
leading legislative efforts to ban the import and land application of sludge, or biosolids, in Kern County.  
The measure, SB 926, cleared the State Senate, but a series of meetings and negotiations indicated
Los Angeles had enough votes to kill the bill in the State Assembly.

Blaming the victim for health effects caused by sludge is the first rule of EPA and its partners. The
health effects reported in this article are the same as those which have been reported where ever
sludge has been dumped as a fertilizer.Since sludge now meets the definition of a biological weapon,
there is no way the state agencies can afford to admit sludge is a problem. No one wants to accept that

To date, there has only been one case involving Part 503 policy and improper sludge disposal which
has been tried and appealed in federal court -- United States vs. Cooper. In part, Cooper went to jail
because of improper disposal of Class B sludge on organic farming land.In that case the Ninth Circuit
Court of Appeals restated the case that sludge is a pollutant under the CWA which must be disposed of

The agreement allows EPA to violate the CWA. In exchange for these commitments, the citizen
[partners] plaintiffs, NRDC, and AMSA agree not to sue EPA for failure to comply with CWA
405(d)(2)(C), preventing additional litigation. The Agreement preserves AMSA's right, however, to
intervene in any CWA 405(d)(2)(C) lawsuit that may be brought by another

Wasn't a similar agreement signed with EPA when the NRDC sued EPA to stop ocean dumping? Who
gave these people in EPA, NRDC, and AMSA the right to create an agreement for EPA to violate the
CWA 405(d)(2)(C) provisions which put the farmers and public at risk

When it comes to human health, dairy cattle deaths are similar to a canary in a mine. If the Canary
dies, the miners know they have a serious problem. The toxic chemical body burden of our children has
been increasing and generally mother's milk has been blamed. No one wants to admit that if the dairy
cows are dying from toxic chemicals and disease organisms, those same toxic chemicals and disease
organisms would pass through to our children in the milk. Why would some EPA, WEF and state
employees go to so much trouble to spread these chemical and biological poisons on dairy farms.
Normally, we would expect only a terrorist would do something like this.

Studies have documented Salmonella infection of cattle grazing on pastures fertilized with toxic sewage
sludge and a cycle of infection from humans to sludge to animals to humans. (Taylor and Burrows.
1971, WHO. 1981, Dorn, 1985).  In September 2002, the USDA research showed that 28 percent of the
beef entering slaughterhouses is now contaminated with the untreatable deadly E. coli 157.

Local Control Lawsuit    LA County v Kern County

Congress Authorized Local Sewage Sludge Ordinances -- AS DOES PART 503

Excerpts from National Sludge Allinace Fact Sheets