WHAT IS NECROTIZING FASCIITIS (MRSA) AND WHY IS IT ON A RAMPAGE THROUGH TUCSON

NECROTIZING BACTERIA CREATING PANDEMIC -- Graphic images of soft tissue and necrotizing infections

Necrotizing fasciitis is the result of an invasive bacterial infection that destroys deep soft tissue in the body very quickly.
As the tissue is invaded and destroyed gas gangrene sets in and the toxic gases generated by the bacteria can create
toxic shock causing death within a few days or in the worse cases, a matter of hours. While a number of bacteria
formerly known for causing relative mild diseases (such as Streptococcus and Staphylococcus) have taken on the
invasive traits in the past 15 years, many writers simply refer to the multiple cast of deadly organisms as the flesh eating
bacteria. The literature suggests scientists are puzzled about the nature of these bacteria and how they transformed
themselves so quickly into the deadly toxin producing strains.

Research indicated an Air Force document, (13) by Dr. Stephen F. Burgess and Dr. Helen E. Purkitt, dated April 2001,
might supply the answer. They state there are specific bacteria that cause necrotizing fasciitis and gas gangrene
[Clostridium perfringens (formerly known as Clostridium welchii), Streptococcus and Staphylococcus -- three
major foodborne contamination bacteria found in sewage sludge]. The document also indicated South Africa got the
bacteria about 1984 and gave the bacteria and antidote to the US government in 1994.

However, the literature shows these super bugs and other are currently being created in our wastewater treatment
plants. The literature also shows that primary exposure routes of infections are through wastewater effluents into
waterways and waste residual disposal as a fertilizer or soil amendment and bioaersols from disposal sites and soil
amendment waste residual compost producing facilities.

Background

According to Dr. Troy A. Callender,(1) it appeared necrotizing fasciitis was a very rare disease at least in the early
1990s.. At a conference held at The Baylor College of Medicine in Houston, Texas. On December 31, 1992, Callender
reported the "The eyelids, scalp, face and neck are rarely involved, with only 40 cases reported in the literature." Six
years later, in 1998, NEW SCIENTIST (2) reported, "In Montreal, Canada, five people came down with group B
streptococcus necrotizing fasciitis from the period of April 1996 to October 1997. This strain is so rare that only four
other cases in the past forty years worldwide had been reported".

However, by 1998 necrotizing fasciitis was fast reaching epidemic status and many scientists began searching for the
root cause of the disease. They first thought it was only invasive group A streptococcal (GAS).

"Unfortunately", said. Dr. Adrienne J. Headley, University of Medicine and Dentistry of New Jersey, in American Family
Physician,(3) July 15, 2003, "necrotizing soft tissue infections have no pathognomonic [distinctively characteristic]
signs." She said, "Necrotizing soft tissue infections are a broad category of bacterial and fungal skin infections. Despite
surgical advances and the introduction of antibiotics, reported mortality rates for necrotizing soft tissue infections range
from 6 percent to as high as 76 percent." Furthermore she said, "Type I infections are mixed infections generated by
anaerobic and facultative bacteria, whereas type II infections generally are caused by group A streptococci.
Staphylococci also may be found in conjunction with group A streptococci."

Dr. Sat Sharma, MD, (5) Program Director, Associate Professor, Department of Internal Medicine, Divisions of
Pulmonary and Critical Care Medicine, University of Manitoba, in a 2004 study, Toxic Shock Syndrome (TSS) states,.
Colonization or infection with certain strains of S aureus [staphylococcal] and GAS [group A streptococcal] is followed
by the production of 1 or more toxins." "The streptococcal TSS is identical to staphylococcal TSS (STSS), except that
the blood cultures usually are positive for staphylococci in STSS." Furthermore, he said, "A history of recent varicella
infection markedly increases the risk of infection with GAS to 62.7 cases per 100,000 people per year. Severe soft
tissue infections, including necrotizing fasciitis, myositis, or cellulitis, were present in approximately half of the patients."
"STSS is much more common, although data on prevalence do not exist. In the United States, from 1979-1996, 5296
cases of STSS were reported.

Michael Maynor, MD, (4) Clinical Assistant Professor, Department of Hyperbaric/Emergency Medicine, Louisiana State
University School of Medicine, agreed with Headly and Sharma in 2005. However, he noted the range of bacteria
associated with the disease was increasing. He said, "In necrotizing fasciitis, group A hemolytic streptococci and
Staphylococcus aureus, alone or in synergism, are frequently the initiating infecting bacteria. However, other aerobic
and anaerobic pathogens may be present, including Bacteroides, Clostridium, Peptostreptococcus, Enterobacteriaceae,
coliforms, Proteus, Pseudomonas, and Klebsiella."

Hackett SP, Stevens DL,(21) 1993, showed, "Superantigens associated with staphylococcal and streptococcal toxic
shock syndrome are potent inducers of tumor necrosis factor-beta synthesis."
They say, "These data suggest that the induction of TNF beta synthesis may be a unique pathway by which
superantigens associated with severe streptococcal and staphylococcal infections mediate shock and multiorgan failure
characteristic of toxic shock syndrome."

Invasive group A streptococci and Staphylococci both cause invasive necrotizing fasciitis, cellulitis, and myositis. One of
the Staphylococci focused on recently is community acquired (CA) methicillin resistant Staphylococcus (MRSA) which is
escalating around the world with some being extremely drug resistant strains..

UNITED STATES

Karen Brande (28) reported in the Tucson Weekly, DECEMBER 22, 1997, a case of a four month old Japanese child
who was infected after undergoing heart surgery. The Japanese authorities were concerned about the serious infection
in 1996. Brandel said, :Japanese authorities sent the bacterial strain to Dr. Fred Tenover's lab at the CDC, which
confirmed the existence of a mutated strain of Staph having intermediate resistance to Vancomycin. Tenover wanted to
quell panic, urging colleagues not to deluge him with questions." Brandel said, "After the two U.S. cases, Tenover
issued a grim report in the Journal of the American Medical Association, raising the specter of quarantines, and urging
physicians and public health officials to seek the public's cooperation in dealing with these resistant pathogens. In his
report, Tenover raised the frightening possibility of a post-antibiotic era."

Gary Mihoces, (9) USA TODAY, reported on 10/15/2003, "David Edell, an athletic trainer who works with 13 high school
football teams in Texas, is no stranger to the antibiotic-resistant skin infection known at MRSA. Edell says two cases of
MRSA have been identified among high school football players he's treated this season. He says he encountered "two
of three" cases last year"

In the same article he noted, "Eight members of the Franklin (Wis.) High School team have been infected since mid-
September, including one hospitalized 16 days because the bacteria got into his blood, according to coach Jesse Miller."
"In August, seven members of the University of Southern California team were infected and four were hospitalized,
according to the Los Angeles Times." "In September, several members of the NFL's Miami Dolphins were infected, and
linebacker Junior Seau and kick returner Charlie Rogers required hospitalization, according to The Miami Herald."
Laurie Goodman (6) reported, in the Journal of Clinical Investigations, 2004, on a meeting of 42nd annual meeting of
the Infectious Diseases Society of America held in Boston. She said, "--findings reported in more than 25 poster
presentations showed a significant increase in MRSA infections in healthy individuals who have none of the usual risk
factors.

In Archives of Pediatric Adolescent Medicine., Oct. 2005, , Purcell K, Fergie J, (7) reported his finding in a a 14-year
study at Driscoll Children's Hospital in Texas the community-acquired (CA) methicillin-resistant Staphylococcus aureus
(MRSA) infections in South Texas children were epidemic. The author found, "A total of 1002 MRSA cases were
identified from 1990 through 2003 of which 928 (93%) were community-acquired. The number of CAMRSA cases
ranged from 0 to 9 per year from 1990 through 1999 and then increased exponentially from 36 in 2000 to 459 in 2003. "
He concluded, "The rapid emergence of CAMRSA as a cause of noninvasive and invasive infections in children, which
started occurring in the 1990s, has reached epidemic proportions"

Anita Manning, (8) USA TODAY, reported on 12/18/2005, "Among the most worrisome of these superbugs is MRSA, or
methicillin resistant staphylococcus aureus, a germ once found primarily in hospitals. But it's popping up so often
outside of health care settings that it is, "arguably, a true pandemic," said Steven Projan of Wyeth Research in
Cambridge, Mass., who spoke at the Interscience Conference on Anti-microbial Agents and Chemotherapy, ending
Monday."

According to her article, "MRSA infections are even showing up in animals, said veterinarian Scott Weese of Ontario
Veterinary College at the University of Guelph, Canada. The bacteria may be passed from people to their pets, and vice
versa, he said."

In the same article she noted the reaction of the drug companies to the emerging antibotic resistant drug threat, "Only
a handful of new antibiotics are being developed to combat these resistant bugs. "There seems to be very little going
into the pipeline," said Richard White, chief scientific officer of Vicuron Pharmaceuticals. Many large drug companies
have dropped antibiotic research and are focusing on chronic diseases, developing drugs that must be taken
repeatedly." "There are more profitable areas to pursue," he said. "The problem with antibiotics is they work, and the
patient is gone in a matter of days."

Medical News Today,(17) 23 Sep 2005, reported, "In a "Brief Report" in the 22 September 2005 issue of the New
England Journal of Medicine, researchers at the University of Chicago describe three cases of rapidly progressive and
ultimately fatal Staphylococcus aureus infections in small children. Although all three children were previously healthy,
the infection caused severe sepsis, rapid clinical deterioration and bleeding into the adrenal glands, a complication,
known as Waterhouse-Friderichsen syndrome, that is usually associated with fulminant bacterial meningitis".

International

Sarah Sims, (15) Leicester Royal Infirmary drug information pharmacist, eplains how serious the drug resistant situation
has become. She said, "When penicillin was introduced in 1944, over 95 per cent of S aureus strains were susceptible.
This has now decreased to 10 per cent. In the 1950s, isolates resistant to penicillin were a major problem. The
introduction of ß-lactamase-stable penicillins (eg flucloxacillin) in the 1960s initially overcame this problem, but was
quickly followed by the development of the first MRSA. Since then most MRSA strains have developed resistance to
most other antibiotic agents. They are consistently susceptible only to vancomycin and teicoplanin. However, recently
there have been reports, first from Japan, then the US and more recently France, of MRSA with intermediate resistance
to vancomycin and teicoplanin. These strains are resistant to all available antibacterial agents."

Canada Communicable Disease Report, (24) July 1, 1997. The report states, "Severe group A streptococcal infections
became reportable in Quebec in March 1995. Twenty-eight cases of necrotizing fasciitis were reported in 1995 and
1996. Two of these cases had Fournier's gangrene (necrotizing fasciitis of the genital area); they were from the same
semi-rural region of Quebec and were ill in October 1996. One other case of Fournier's gangrene, also from the same
region, occurred in July 1996." Disease report editor's comments, "Surveillance from Canada and the United States
indicates that necrotizing fasciitis (NF) represents between 6% and 10% of all invasive group A streptococcal infections
(1,2). Group A streptococcal necrotizing fasciitis is particularly devastating when it is associated with the streptococcal
toxic shock syndrome, with case fatality rates over 50%.

In France, Patrica Minary-Dohen et al.(14) Reported in BMC Geriatrics 2003, "Methicillin-resistant Staphylococcus
aureus (MRSA) strains were first identified in the early 1960's [1]. They now have a worldwide distribution [2] and have
evolved resistance to multiple antibiotics. The recent description of clinical strains highly resistant to glycopeptides
following the acquisition of the vanA gene has increased fears that it will soon be impossible to treat patients infected
with these epidemic strains [3]. The prevalence of MRSA in France is among the highest in the European Union [4,5],
and a recent publication by a regional surveillance network showed that this prevalence continued to increase between
1996 and 2000 [6].

In England, Jenny Booth, (10) reported on a British soldiers death by MRSA infection in the British news, Times Online,
May 24, 2005. In her article she quoted research led by Dr. Enright which was published in Lancet medical journal April
2005. , "The new strain is a mutation of a bacterium that caused a global epidemic in the late 1950s, killing thousands in
the UK and worldwide."

She said. "Once the PVL-[toxin]-producing disease progresses from infecting the skin to attacking the organs, it is fatal
in up to 75 per cent of cases, as diagnosis and treatment are generally too late to stop deadly amounts of PVL toxin
building up in the body. The PVL kills the white blood cells which are the body's main defense against disease." The
British Department of Health told Booth, "The available evidence doesn't illustrate that this is a cause for concern. It is
important not to panic people. There is already enough panic about MRSA."

Clara Penn reported in New Scientist, April 2005 , "An international team of scientists has found that a strain of CA-
MRSA known as the southwest Pacific clone is closely related to an older form of Staphylococcus aureus that caused a
pandemic in the 1950s." "The southwest Pacific clone has spread into Europe, where it has caused fatal pneumonia in
France, Sweden and Latvia. Only two specimens have so far been found in the UK."
According to J.J. Green, (27) Federal News Radio,Mar. 22, 2005,

"U.S. troops are coming home from Iraq and Afghanistan with what some are calling a mysterious super bacteria. But
what is it, and how did they get it?

"It's a flesh eating bacteria that is coming out, and this is the one they are not talking about," says Patricia Hellinger, a
Montana-based health writer.

Hellinger says a lot of troops are coming to Walter Reed Army Medical Center with this bacteria. So what does Walter
Reed have to say?

"The first response would have to be a simple no," says Col. Joel Fishbain, an infections disease specialist at Walter
Reed.

Col. Fishbain says it's not flesh eating, and not a super-bacteria, but it is an increasingly drug-resistant bacteria.
"What we've seen in our soldiers returning with injuries is a lot of colonization and some infections with an organism
called acinetobacter baumanii."

The Centers for Disease Control says troops who are shot or injured in Iraq or Afghanistan are at risk because the
bacteria is in the soil and the air"

In a 2001 study,(26) Nosocomial infections due to Acinetobacter baumannii in a neurosurgery ICU, Gulati SS, et al,
found, "Invasive infections caused by Acinetobacter baumannii in a post-operative neurosurgery ICU were studied. Sixty
one patients admitted during a span of 11 months were culture positive for acinetobacter species from blood and/or
CSF samples. They were followed up prospectively for evidence of infection and clinical outcome. 40 cases had clinical
evidence of infection due to acinetobacter species while in 21 patients, the isolation of the organism was considered a
contaminant. Acinetobacter baumannii was the most common organism associated with invasive infections. Respiratory
tract was found to be the most common primary source of infection in patients with bacteraemia or meningitis. The age,
sex and pre-operative hospital stay were not significantly different in the two groups (p>0.05), while post-operative
hospital stay and mortality was significantly higher in patients with invasive infection (p<0.05). Acinetobacter baumannii
was isolated from multiple sites (p<0.05) and repeatedly from the same site (p<0.001) in a significantly higher number of
patients with invasive infections. Mortality was high in the patients infected with Acinetobacter baumannii. Even amongst
the infected group, the patient shaving meningitis showed a higher mortality as compared to the patients having
bacteraemia."

Medical News Today, (18) reported on 13 Jan 2006, Supersized 'island' Of Resistance Genes Discovered In An
Infectious Bacterium, "Researchers have discovered a cluster of 45 genes coding for antibacterial drug resistance in the
bacterium, Acinetobacter baumannii, a major cause of hospital-acquired infections worldwide. The study was reported in
the open-access journal PLoS Genetics" "We expected to find resistance genes," said lead author, Pierre-Edouard
Fournier, researcher at the Structural and Genomic Information Laboratory at France's National Center for Scientific
Research (CNRS). "But the grouping of most of these genes within a single genomic island was totally unexpected." The
resistance island--a group of resistance genes clustered close together on a chromosome--is the largest discovered to
date. "The research team also discovered new resistance genes. "We were surprised to discover 19 new resistance
genes that escaped the scrutiny of the large number of laboratories already working on multi-drug resistant A.
baumannii throughout the world."

Tucson, Arizona - From invasive necrotizing group A streptococcal to invasive necrotizing Staphylococcus.

Journal of the American Medical Association, (19) 1993 Jan 20, published a CDC study in Pima County showing a
disturbing trend as Streptococcus infections progressed from a few cases of a serious but curable disease to fatal toxic
shock syndrome between 1985 and 1990.

Hoge CW, et.al. (CDC) said, "We retrospectively surveyed microbiology records from all 10 hospitals in Pima County,
Arizona, to identify patients who had Streptococcus pyogenes isolated from blood, sterile body fluid, or tissue biopsy
specimens between April 1985 and March 1990" They found, "A total of 128 patients with a median age of 53.5 years
(range, 6 months to 96 years)."

The results of the study found, "The annual age-adjusted incidence was 4.3 per 100,000 but was 46.0 per 100,000
among Native Americans. Advanced age, age less than 5 years, hypotension, and multi-organ system involvement were
significantly associated with increased mortality. From 1985 to 1990, the proportion of infections with hypotension, rash,
desquamation [Partial loss of the epidermal basal cells-- Dryness, itching, scaling, flaking, and peeling- Hyper
pigmentation], renal impairment, and gastrointestinal involvement increased significantly (chi 2 for trend P < or = .02 for
each feature). A toxic shock-like syndrome occurred in 8% of infections since 1988, compared with none of the
infections between 1985 and 1987 (P = .04)".

The CDC conclusion, "Significant changes occurred in the spectrum of invasive group A streptococcal infections in Pima
County, Arizona, between 1985 and 1990. Native Americans were at increased risk of acquiring these infections."

Karen Brandel, reported in Tucson Weekly, DECEMBER 22, 1997, "In 1990, Tucson saw an outbreak of invasive Strep
A, according to Ken Komatsu, of the Arizona Department of Health Services. The number of cases increased so
dramatically that the state mandated emergency measures, requiring physicians to report every case for an 18-month
period. In October 1993, the state again added Invasive Strep A to the list of diseases that must be reported to the
Health Department. So far, in 1997, Arizona had 110 such cases."

Acording to Carla McClain, (11) Arizona Daily Star, 12/04/2005, (Pima County and the City of Tucson), "A single
emergency room, at Tucson Medical Center, has treated 541 cases this year — triple the number TMC saw in 2003."
Furthermore, the University Medical Center, has had 483 MRSA cases in its emergency or urgent care center in the
past year.

At first glance 2.8 cases a day (1,024) of MRSA at two Tucson hospitals may not seem like a major cause for concern
for a county population estmated at 907,059 for 2004. That works out to 113 cases per 100,00 people, with only two
hospitals reporting infections, a dramatic increase in the past 15 years since the CDC investigation ended in 1990.
However, Tucson and Pima County have 10 hospitals. Information on infections was not furnished on the other 8
hospitals.

Jenny Rose, (12) KGUN TV, 12.19.2005, reported that "Firefighters are trying to protect themselves from an aggressive,
flesh-eating bacteria. The number of firefighters contracting MRSA is on the rise. In the past year, four firefighters in the
Tucson area have contracted MRSA. That may not sound like much, but physicians have seen more MRSA cases in the
last six months than they have in five years" She reported, "In July, a mosquito bite on Brian Barrett's arm became
infected with MRSA."

Dr. Sean Allot, (11) a University of Arizona pediatrician who handles MRSA in young patients handled nearly 30 entire
families affected by it in 2005. "This is a big one," he said. "It's not a cause for panic yet, but it's a bad player."

MRSA has been misdiagnosed as bee stings, spider bites, etc.. Like bee stings and spider bites, immediate medical
attention is required. If these infections are not detected and treated quickly, the infection invades the soft tissues of the
body and must be surgically removed. Misdiagnosis or delayed diagnosis and treatment leads to lost of limbs or death.
Fortunately, invasion of tissue only develops in a small percentage of MRSA infections.

According to McClain's article (11), the State of Arizona only started tracking severe, invasive cases of MRSA last year
and now average 125 a month statewide. She said, "To date, 1,305 invasive cases have been reported, with 132 in
Pima County. Deaths have not been tracked."

BACTERIA AND VIRUSES EVOLVING INTO MORE DEADLY ORGANISMS IN WASTEWATER TREATMENT PLANT
AND WASTE RESIDUALS (SLUDGES)

In M. C. Meckes' (20) (EPA February 1982), study Effect of UV light disinfection on antibiotic-resistant coliforms in
wastewater effluents.

Meckes' study found, "Total coliforms and total coliforms resistant to streptomycin, tetracycline, or choramphenicol were
isolated from filtered activated sludge effluents before and after UV light irradiation." "--the percentage of the total
surviving coliform population resistant to tetracycline or chloramphenicol was significantly higher that the percentage of
total coliform population resistant to those antibiotics before UV irriation." "Multiple drug resistance patterns of 300 total
coliform isolates revealed that 82% were resistant to two or more antibiotics. Furthermore, 46% of these isolates were
capable of transferring antibiotic resistance to a sensitive strain of Escherichia coli."

He found, Total coliform isolates transfering antibiotic resistance to Streptomycin --
Before U V irradiation 19 isolates gathered, (38) percent of the isolates were resistant.
After   UV irradiation   32 isolates gathered, (64) percent of the isolates were resistant.

He also quoted earlier research, "In 1959, Wantanabe (31) discovered that some Escherichia coli strains could transfer
antibiotic-senstive strains of shigella spp. Subsequent research has demonstrated that bacteria carrying transmissible R-
factors are responsible for the spread of multiple antibiotic resistence among members members of the Entero-
bacteriaceae (such as E. coli, Samonella typi, and Shigella dysenteriae) Aeromonas and Yersinis species (4),
Pseudomonas, and Vibro cholerae (34),"

Meckes' said, "From late 1968 to early 1981, Central America was afflicted by and R+ S. dysenteriae pandemic (11).
During the first year of the epidemic, in Guatemala alone, 12,500 deaths were recorded."

In conclusion, Meckes' remarked, "It is important to remember that isolates in these experiments were tested for
resistance to only eight antibiotics, and consequently, resistance to other antibiotics may be carried by these organisms."
In a recent EPA document,(32) EPA said, "A recent prominent case of transfer of virulence concerns the well published
case of enterohemmoraghic E. coli O157:H7 (58). In this case, a previously less pathogenic strain of E.coli acquired a
shiga-like toxin as well as other changes, which created a more virulent pathogen. There are currently not enough data
to determine whether transfer of genes between biocontrol strains and clinical strains of Bc could be important for
increasing pathogenicity. In the absence of detailed information, based on the common ability of bacteria to share
genetic material in various environments, it is reasonable to assume that this ability exists in Bc. There is considerable
evidence that a number of human pathogens engage in horizontal gene transfer of virulence genes (34).

In 1981, Canadian researcher J B Bell, et al.,(33), found, "Coliform and fecal coliform populations found in the raw
sewages and final sewage effluents of the prairie provinces and the Northwest Territories were examined for antibiotic
resistance and the possession of R factors. It was determined that 8.91% of the total coliform and 10.80% of the fecal
coliform populations carried R factors. The following numbers of combinations of R determinants were found: 39 in the
Escherichia coli population, 6 in the Citrobacter population, 20 in the Enterobacter populations, 10 in the Klebsiella
populations, and 11 in the Aeromonas populations. The maximum number of R determinants transferable
simultaneously was seven; organisms with R factors containing determinants for chloramphenicol usually contained
determinants for ampicillin. Of the coliform and fecal coliform populations, 2 to 4% were resistant to chloramphenicol in
some provinces, and from 17 to 30% of the populations were resistant to three or more antibiotics. It was calculated that
coliforms containing R factors in the raw sewage reached population levels of 1.5 X 10(7)/100 ml, and fecal coliforms
containing R factors reached population levels of 8.6 X 10(5) ml. Final effluent discharges to the receiving environment
contained R factor-containing coliform and fecal coliform populations of 3.1 X 10(4)/100 ml and 5.8 X 10(2)/100 ml,
respectively. The incidence of bacteria containing R factors in sewage appears to be increasing with time, and their
removal from sewage before discharge to the receiving environment is desirable. Consideration of data on bacteria with
R factors should be made in future water quality deliberations and in discharge regulations."

Cornell Studies (47) have also documented the acute toxicity of organic pollutants in sewage sludge (which the EPA
does not address in the beneficial use regulation) and that the pollutants in sludge may not leave any indication in the
body as to the actual cause of death. (Babish. 1981, 1985).

Bio Med Net (22) article, 24 September 2003.   Bacteria learn antibiotic resistance in the sludge According to the article.
"Bacteria residing in the sludge of a municipal water treatment plant contain integron-specific DNA sequences, says
Alfred Pühler, a microbiologist at the University of Bielefeld in Germany. Such sequences are virtually absent from soil
samples, he says, so their presence in this environment indicates that sludge is "a specific location where genes are
coming together and being distributed." "Furthermore, analysis of effluents from the plant reveals that bacteria
containing integron-specific sequences on plasmids are being released into the environment. "You have to block the
release of bacteria from wastewater treatment plants," urged Pühler."

Leen De Gelder et al., (23) September 2005, Department of Biological Sciences, Initiative for Bioinformatics and
Evolutionary Studies, University of Idaho, Moscow, Idaho, found, "Plasmid Donor Affects Host Range of Promiscuous
IncP-1ß Plasmid pB10 in an Activated-Sludge Microbial Community." The authors said, "In this study we show that the
host range of a broad-host-range plasmid within an activated-sludge microbial community was influenced by the donor
strain and that various mating conditions and isolation strategies increased the diversity of transconjugants detected"

They found, "The phylogenetic diversity of transconjugants obtained in separate matings with donors Pseudomonas
putida SM1443, Ralstonia eutropha JMP228, and Sinorhizobium meliloti RM1021 was significantly different. For example,
the transconjugants obtained after matings in sludge with S. meliloti RM1021 included eight genera that were not
represented among the transconjugants obtained with the other two donors. Our results indicate that the spectrum of
hosts to which a promiscuous plasmid transfers in a microbial community can be strongly influenced by the donor from
which it transfers."

"The National Academy of Science 's (NAS) recent (July 2002) Committee Report on Toxicants, states that it is
impossible to do a risk assessment to prove sludge use under part 503 is safe. The scientific statement is very blunt:
FINDINGS,"-----the remaining uncertainty for complex mixtures of chemical and biological agents is sufficient to preclude
the development of risk-management procedures that can reliability result in acceptable levels of risk." (5)

WHAT CAN WE EXPECT FROM SLUDGE DUMPED AS A FERTILIZER

Pathogens in Class A Sludge

EPA's Technical Support Document for composting (Occurence of Pathogens in Distribution and Marketing Municipal
Sludges, (Yanko, 1988) Yanko states, "Although the use of sludge as a soil amendment is attractive, it is not without
potential health risk. Toxic chemicals, including heavy metals and industrial organics may enter the food chain and
present long-term health risks. Pathogenic mircooganisms present in sewage and the resulting sludges [E. coli
(pathogenic strains), salmonella sp. Campylobacter jejuni, Yersinia, enterocolitica, Lepotospira spp.,Shigella spp. and
bibrio cholerae] increase the potential for disease transmission." Yanko also statess, "Salmonellosis outbreaks that may
have been initiated by infectious doses as low as 10-100 cells have been described in the literature. It would certainly
appear imprudent to overlook moderate salmoneeae populations because of "convential wisdom" concerning infective
doses."

Furthermore, "The relative public health risk associated with the beneficial use of sludge is directly related to the extent
of public exposure.----risks increases if the sludge is used on food crops or public access areas. ---The routes of
exposure may take various forms, including handwork in gardens and eating uncooked vegetables, grown in sludge
amended soils---Perhaps at the highest risk of ingesting pathogenic organisms are the very young children playing in
yards and gardens that have been treated with sludge products.

Yanko also warns of the fungi that can be found in compost, "such as certain specious of Candida. Cryptocuccus and
Trichosporon, and PATHOGENIC members of some filamentous genera, such as Aspergillus, Phialophora, Geotrichum,
Trichophyton, and Epidermophyton." Also, "Parasitic infections present a potential health risk associated with home use
of sludge due to the existence of highly resistant stages of the organisms and low infectious doses."

"When University of Arizona researchers,(37) Straub, Pepper and Gerba (1993) reviewed the literature to assess the
microbial (bacteria, viruses and parasites) risks associated with application of sludge to agricultural land, they found that
"despite a 1-2 log 10 decrease in bacterial and viral number, significant concentrations of these pathogens persist after
sludge treatment (Pepper and Gerba 1989; Soares 1990)." (p. 70)

Furthermore, most methods used in the detection of pathogens were not 100% efficient and concentrations were always
underestimated. They also discovered that methods did not
exist for the detection of all pathogens that the sludges could contain. They stated that "It would not be unreasonable to
suggest that the actual concentrations of enteric viruses are 10-100 times the number observed experimentally". (p. 81)

In their summary of the review of the literature, Straub, Pepper, and Gerba state the various risks found to public health
from the microorganisms in the sludge applied to the land:

Endotoxins a serious threat for respiratory diseses in Class sludge/biosolids

CDC information, (62) "Endotoxins, which occur in the outer membrane of certain gram-negative bacteria, are not
secreted but are released only when the cells are disrupted or destroyed. Endotoxins are complex polysaccharide
molecules that elicit an antigenic response, resulting in fever and altered resistance to bacterial infections. Exposure
may cause toxic hemorrhagic shock and severe diarrhea."

Edwards JH., (29) Organic dust diseases and endotoxins, 1981, writes, "On the basis of available information it is not
justifiable to conclude that endotoxins are responsible for extrinsic allergic alveolitis by biological activities that are
associated with endotoxin properties per se. Endotoxin-like material has been found in materials associated with
byssinosis, farmer's lung and sewage sludge disease and a case for their involvement in the aetiology of byssinosis and
sewage sludge disease can be made out. However, endotoxin-like activity in farmer's lung is less important than the
hypersensitivity reaction except possibly where heavy doses of mouldy hay dust are inhaled. The indirect role of
endotoxin in promoting a hypersensitivity response, i.e. by adjuvant activity, etc., is undoubtedly more important than is
its direct action in this disease."

Canadian OSHA (30) states, "The term extrinsic allergic alveolitis refers to a group of lung diseases resulting from
exposure to dusts of animal and vegetable origin. The name, although complicated, describes the origin and the nature
of these diseases." "Intense or prolonged exposure to animal or vegetable dusts can result in extrinsic allergic alveolitis.
The dust particles must be 5 microns or smaller to get into the alveoli. Animal and vegetable dusts are complex mixtures
originating from many different sources such as husks, bark, wood, animal dander, and microorganisms including
bacteria and fungi.

The microorganisms produce toxic chemicals that form part of the mixture." " The allergy is triggered by complicated
reactions of the body's natural defense system that normally protects the lungs from foreign substances. In some
individuals, the chemical reactions of the defense system that would ordinarily protect the lungs actually cause the
inflammation and lung damage."

"The acute attack is triggered by heavy exposure to dust. It starts with fever, muscular aches and a general, unwell
feeling or malaise. These symptoms are accompanied by tightness in the chest, a dry cough, and shortness of breath."
"The sub-acute response occurs most frequently to people exposed to relatively low levels of dust. It is marked by
cough, shortness of breath, sweating, sore throat, headache, and nausea."

"The chronic response develops after persistent acute attacks and recurrent sub-acute responses. It is marked by
increasing shortness of breath, occasional fever, loss of weight, and general lack of energy. The victim suffers
permanent lung damage and, in the worst cases, death may occur." One disease is "Sewage sludge disease" caused by
"Dust of heat-treated sludge."

In Australia, (31) recognizes sewage sludge as a source of antigens which can trigger the disease in a statement of
principles. " 1. This Statement of Principles is determined by the Repatriation Medical Authority under subsection 196B
(2) of the Veterans' Entitlements Act, 1986 (the Act). Kind of injury, disease or death
2. (a) This Statement of Principles is about extrinsic allergic alveolitis and death from extrinsic allergic alveolitis. (b) For
the purposes of this Statement of Principles, "

allergic alveolitis" means an immunologically induced inflammation of the lung parenchyma involving mainly the alveoli
and terminal bronchioles, which develops secondary to repeated inhalation, by a sensitised subject, of any one of a
variety of antigens, attracting ICD code 495. Extrinsic allergic alveolitis is associated with a restrictive pattern of
respiratory function tests. Examples include farmer' lung, bird-fancier' lung, ventilation pneumonitis and woodworker'
lung.

. " source" means the source of the antigen responsible for causing extrinsic allergic alveolitis. Examples of antigenic
sources include: Sewage sludge contaminated with micro-organisms, Fertilizer contaminated with micro-organisms,
Compost dust contaminated with micro-organisms"

A published Peer Reviewed .,(23) (2004) Canadian study shows, "Increased frequency of drug-resistant bacteria and
fecal coliforms in an Indiana Creek adjacent to farmland amended with treated sludge." According to Shivi Selvaratnam
et al., "The goal of this study was to determine whether the frequency of drug-resistant and indicator bacteria in Sugar
Creek, which is used for recreational purposes, was influenced by proximity to a farmland routinely amended with
treated sludge (site E). Surface water from 3 sites along Sugar Creek (site E, 1 upstream site (site C) and 1 downstream
site (site K)) were tested for the presence of ampicillin-resistant (AmpR) bacteria, fecal and total coliforms over a period
of 40 d. Site E consistently had higher frequencies of AmpR bacteria and fecal coliforms compared with the other 2
sites. All of the tested AmpR isolates were resistant to at least 1 other antibiotic. However, no isolate was resistant to
more than 4 classes of antimicrobials. These results suggest that surface runoff from the farmland is strongly correlated
with higher incidence of AmpR and fecal coliforms at site E."

In 2004, the Pakistan Agriculture Research Department, (60), commissioned the sludge study, Impact of sewage wastes
(effluent sludge) on soil properties and quality of vegetables.

Dr. Muhammad Qasim Khan, Department of Soil Science, Gomal University, D.I.Khan, found, "The bacteria species
isolated

from effluents were E. coli, Salmonella spp., Streptococcus spp., Pseudomonas spp., Proteus spp. & Staphylococcus
spp.;

from the- sludge it was E.coli. Staph aureus, Streptococcus spp., Bacillus subtilus & Pseudomonas spp. from the soil
E. coli, Salmonella spp., Pseudomonas spp., Staphylococcus spp. & Bacillus spp., &

from the vegetables were E.coli, Staph.aureus., Staph citreus & Bacillus megatarium, Fungi identified from the
effluents were, Aspergillus spp., Mucor spp., Alternaria spp., Geotrichum spp., & Trichoderma spp. in the sludge Mucor
spp., Geotricum spp., Rhizopus spp., Aspergillus spp., Alternaria spp. & Penecillium spp.

in the soils Aspergillus, Coccidiodes spp., Mucor spp., Paeciliomyces spp. Fusarium spp. & Geotriticum spp., &
in the vegetables were Xanthomonas spp., Mucor spp., Rhizopus spp. & spergillus spp.
Number of Coliform bacteria per 100 gram of vegetables treated with sewage wastes ranged from 48 to 160 with
maximum in effluents treated lettuce getting E7 treatment. Data on growth & yield parameters of vegetables revealed
that increase in all the growth parameters was higher in NPK treatments followed by S7, S6, E7 & E6 as compared to all
other treatments."

Iin South Africa, (61) M Sidat, F Bux* and HC Kasan , Polyphosphate accumulation by bacteria isolated from activated
sludge (1999) Centre for Water and Wastewater Research, Technikon Natal, made in important point in their study,
They reported, "Lötter (1985) reported gram-negative organisms to be the dominant organisms in the activated sludge
system. Results illustrated in Fig. 2 indicate the predominance of gram-positives in the sludge, found to be 42% of the
total poly-P population. These results support work by Brodisch and Joyner (1983) who reported the predominance of
gram-positive organisms throughout their laboratory-scale activated sludge system. They reported the gram-positive
population to be 34.5% in the aerobic zone. The figure also indicates that Staphylococcus spp. were the predominant
gram-positives, forming 40% of the gram-positive population isolated from the sludge followed by Streptococcus spp.
(30%), Micrococcus spp. (20%) and Bacillus sp. (10%). Bacillus cereus, Micrococcus spp., Staphylococcus epidermidis
and Streptococcus spp. showed reasonably high phosphate-accumulating ability in consecutive descending order
respectively.

in 2005, the California Department of Health Services showed how the contaminated runoff from a sludge site could
be dangerous for some people. The report said, "The only surface water sampling obtained by DHS was collected by
the Los Angeles Department of Water and Power, at the Adelanto Converter Station (ACS) on February 12, 2005 and
February 24, 2005.

The ACS is located on the adjacent property directly north of Nursery Products. Six samples of runoff water from four
locations on the ACS property were collected and measured for total coliforms, fecal coliforms, and Escherichia coli (E-
coli). The laboratory analysis revealed high levels of these pathogens in all of the samples—total coliforms ranged from
300,000 to 1,100,000 MPN/100 ml (most probable number per 100 milliliters of water); fecal coliforms ranged from
50,000 to 800,000 MPN/100 ml, and E-coli ranged from 50,000 to 280,000 MPN/100 ml. "

The report stated, "In studies discussing potential exposure to pathogen-contaminated dust and runoff water from land-
applied biosolids and composting (biosolids and green/yard waste), the health concerns reported by the adjacent
communities show similar patterns (NRC 2002, Herr 2002).

Symptoms commonly reported include respiratory infections, skin rashes, burning eyes, burning lungs, difficulty
breathing, and gastrointestinal effects. These effects can be more severe in immunocompromised individuals,
individuals with chronic disease, and other sensitive populations. Similar health effects have been observed in workers
at composting and sewage treatment facilities. In some studies, workers have been shown to have higher rates of airway
mucous membrane complaints, respiratory inflammation, skin rashes, and diseases involving immunological
hypersensitivity reactions (Gattie 2004, Herr 2002)."

In closing the report stated, ". As acknowledged by the NRC, the USEPA, and other experts in the field, many
uncertainties need to be addressed in understanding the full range of public health issues associated with land
application and composting of biosolids"

As an example in 1992, EPA's David Lewis' study, Interactions of pathogens and irritant chemicals in land-
applied sewage sludges (biosolids), found, "Affected residents lived within approximately 1 km of land application
sites and generally complained of irritation (e.g., skin rashes and burning of the eyes, throat, and lungs) after exposure
to winds blowing from treated fields. A prevalence of Staphylococcus aureus infections of the skin and respiratory tract
was found. Approximately 1 in 4 of 54 individuals were infected, including 2 mortalities (septicaemia, pneumonia). This
result was consistent with the prevalence of S. aureus infections accompanying diaper rashes in which the organism,
which is commonly found in the lower human colon, tends to invade irritated or inflamed tissue."

[septicaemia, pneumonia are caused by invasive MRSA]

Lewis' conclusion: "When assessing public health risks from applying sewage sludges in residential areas, potential
interactions of chemical contaminants with low levels of pathogens should be considered. An increased risk of infection
may occur when allergic and non-allergic reactions to endotoxins and other chemical components irritate skin and
mucus membranes and thereby compromise normal barriers to infection."

WHAT OTHER HEALTH PROBLEMS CAN THE PUBLIC EXPECT?

Invasive bacteria and viruses are not the only health problem caused by the exposure to sewage sludge disposed of on
farms, dairies, home lawns and garden, parks, forest and school grounds.

Other health problems are from food poisoning and waterborne diseases.

"(Food Safety from Farm to Table,(64), A Report to the President, May 1997) According to the CDC's Dr. Davis
Swerlow, the problem has been getting worse. As an example, "Between 1982 and 1992 there were 15 reported deaths
from of E. coli .

Now there are an estimated 200 to 250 deaths and 20,000 cases of E. coli-imduced disease reported every year in the
United States."

"The federal agencies, EPA, HHS, and USDA, 1994 report from The Council for Agricultural Science and Technology
which indicates "6.5 to 33 million annual illnesses in the United States food related.", and 9,000 deaths are attributed to
food poisoning. (p.8) "

In a paper presented at the Fourth World Congress on Environmental Health, Environmental Health - A Global
Challenge, in Aberdeen, Scotland, Ralph J. Touch, Chief Sanitarian, for the Department of Health and Human Service
quotes CDC in referring to the 80 million food poisoning incidents in the United States. (Emerging Infectious Diseases,
May, 27-31, 1996)

In 1999, Raymond Singer, Ph.D. (34),   found there was Neurotoxicity from Municipal Sewage Sludge, He evaluated "the
neurobehavioral effects of municipal sewage sludge in a family whose members were exposed for 8 or more years." He
notes, "Municipal sewage sludge, a mixture of household sewage along with industrial waste, is routinely applied as
fertilizer to some farms in the USA". He states, "This complex substance poses a significant neurotoxic threat to farmers,
their workers, nearby residents, and possibly to the general population through the food supply."

What he found, "Based on results of the Neurotoxicity Screening Survey, symptoms consistent with neurotoxicity were
found in all who completed the test. The two children born and raised on the farm have been classified by their schools
as mildly retarded and having attention-deficit disorders, although there was no family history of these illnesses. Similar
results were found in numerous family members."

MILWAUKEE (56) (AP) 2004, — A virus recently discovered in Japan is suspected in two "crib deaths" in Wisconsin,
raising questions about how many of these mysterious deaths might be caused by germs. The cases mark the first time
that the virus has been identified in the United States. Whether it killed the babies is not clear, but both were sick before
they died and had signs of disease in their lungs.

These are just a few of the many health problems that may be associated with exposure to sewage sludge, even if it is
called biosolids.

EPA and what it knows about pathogens

William Sanjour (57) (EPA retired) pointed out the problem with EPA in 1992, "Congress had the best intentions when it
created the EPA, but it did not provide for the checks and balances that we expect in our democratic systems." Sanjour
gives us an example, "When the government agencies perform badly and are called on the carpet by Congress or the
press, they traditionally whine that they weren't given enough money, time, people, authority, etc. Congress, not
knowing whether this is true or not, usually ends up giving them more of everything. Thus they are rewarded for
incompetence and enlarge the bureaucracy with more money, more people and more power with which to be even more
incompetent."

Sanjour also gave us a dire warning, "We's got to deal with regulatory agencies based on what they really are and what
we know about them, not what we would like them to be. Realism must replace idealism. It would be chaos to do without
regulatory agencies, but it is folly to trust them."

We found examples of this for landfill disposal of chemicals in 1991 and beneficial use disposal of chemical and
pathogens as a safe fertilzer in 2004.

In 1991, EPA (58) changed the Solid Waste Rules to require that states complete a cancer risk assesment for over 200
chemical in sludge when it was disposed of in a municipal co-disposal landfill under part 258..

As proposed, the design goal (of a new sanitary landfill) would be to an overall ground-water carcinogenic risk level
established by the State. At a minimum, the design goal under the Part 258.40(b) regulation for cancer risk would have
to fall within the protective range of 1 in 100,000 and 1 in 1,000,000 and encompass risks posed by over 200 hazardous
constituents [chemicals] listed in the proposed appendix II. (FR. 56, p. 51057-1991).

These design goals for a very restrictive Part 258 landfill accepting sludge for disposal were in sharp contrast to the
cancer risk of 1 in 10,000 for organic chemicals used in the development of the proposed Part 503 Sludge use policy.
Particularly, since EPA decided not to regulate any organics in the final 1993 Part 503. Nor did EPA evaluate any cancer
risk pathways for the toxic metals in the final regulation.

According to EPA, the solid waste sludge co-disposal regulation, Part 258, sets forth minimum national Criteria for the
location, design, operation, cleanup, and closure of municipal solid waste landfills. An MSWLF that does not meet these
Criteria will be considered to be engaged in the practice of "open dumping" in violations of (CWA) section 405 of the
RCRA. Moreover, MSWLFs failing to satisfy these Criteria will be deemed to be in violation of sections 309 and 405(e) of
the Clean Water Act if they are receiving sewage sludge. The purpose of part 258 is to establish minimum national
Criteria for municipal solid waste landfills, including MSWLFs used for sewage sludge disposal. Effective date of part 258
was October 9, 1993. (FR 56, p. 51039

The Part 258 regulation identified eight metals to be analyzed during the first phase of ground water monitoring:
Arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. -- copper, nickel and zinc were added as well
as antimony, beryllium, cobalt, thallium, and vanadium ---because the Agency believes that the metals pose serious
threats to human health and the environment.

Yet, EPA said, "1) there is insufficient technical information, particularly, EPA-approved risk levels for many (of the 200)
appendix II constituents; 2) States and owners and operators do not have the technical expertise or resources to
develop the risk based standards for all appendix II compounds; and (3) it may be difficult to obtain public acceptance of
a risk-based design based on standards for appendix II compounds that have no EPA established risk levels." (FR. 56,
p. 51059)

EPA couldn't do a risk assessment for a landfill, yet claimed to do a risk assessment for beneficial use. Then said that
wasn't true.

EPA knowledge of Pathogens documented

January 2004 (59)
RECAP/NEEDS FOUND FOR PATHOGENIC MICROORGANISMS
AND THEIR FATE IN THE ENVIRONMENT
By J. E. Smith, Jr., USEPA, Cincinnati, OH   (EPA's Pathogen Risk Assessment Expert)

He said, "Little experience is available for conducting a quantified microbial risk assessment. The application of microbial
risk assessment demands better data on infectious dose and the survival and transport of specific pathogens during the
land application of wastes."

"The report of a 2001 jointly sponsored USEPA-US Department of Agriculture expert meeting on Emerging Infectious
Disease Agents and Issues Associated with Animal Manures, Biosolids and Similar Byproducts is in press (Smith, Jr. et
al., 2004). Several issues and research needs were identified at the workshop and in related literature. New organisms
of concern were identified including the bacteria: E. coli O157:H7, Listeria, and Helicobacter; viruses: Poliovirus,
Coxsackievirus, Echovirus, Hepatitis A, Rotavirus, and Norwalk agents; and parasites: Cryptosporidium, Cyclospora,
Toxoplasma, Microsporidia, Balantidium, Giardia, and Entamoeba."

CINCINNATI - JUNE 2001 - EPA WORK PROJECT - RESEARCH SCIENTISTS DETAIL UNANSWERED QUESTIONS
ABOUT SLUDGE PATHOGENS AND RISKS TO HUMAN HEALTH >>
EXCERPTS FROM THE 280 PAGE DOCUMENT RESULTING FROM

"WORKSHOP ON EMERGING INFECTIOUS DISEASE AGENTS AND ISSUES ASSOCIATED WITH ANIMAL
MANURES, BIOSOLIDS AND OTHER SIMILAR BYPRODUCTS"

VERNON-MANOR HOTEL, CINCINNATI, OHIO JUNE 4-6, 2001 --
EPA CONTRACT NO. C7-68-0011 Work Assignment 3-98

THE ORGANIZERS: Dr. Patricia Millner, USDA, Dr. John Walker, US EPA, Robert Bastian, US EPA, Robert Brobst, Reg.
8 US EPA, John Cicmanec, Veterinarian, Dr. G. Shay Fout, EPA Virologist, Mark Meckes, EPA microbiologist, Dr. Frank
Schaefer, Parasitologist, Dr. Stephen Schaub, EPA Virologist, and Dr. Jim Smith, EPA PEC (Pathogen Equivalency
Committee) chair.

Page 63 - "What role current waste disposal practices, including land application, may play in the larger picture of
spreading antibiotic resistance is UNKNOWN, and addressing the question will be difficult."

Page 69 - "The1983 Project Conclusions. 1. All of the sewage sludge products examined were found to contain
variable densities of indicator microorganisms. Some products contained bacterial pathogens at high frequencies and
levels. Variability of microorganism concentrations was often great between different facilities and between different
samples from the same facility. Many of the observed trends would not have been detected without a large number of
samples collected over a long period of time.'

Page 71 - "3. Composts modified with various materials to produce commercial soil amendments contained significantly
higher concentrations of bacteria and fungi than the base compost material. The data suggested a nutrient related
REGROWTH phenomenon."

Page 73 - "If we accept that 0.32 percent of the E coli population in sewage derived material may be toxigenic, that
translates to the potential for a Class A product to theoretically contain up to 3 toxic producing E. coli per gram. That is
slightly higher than the limit for Salmonella, but represents a relatively insignificant risk.

IN CONTRAST, Class B anaerobically digested biosolids, receiving no further treatment, could theoretically contain
6,400 toxic producing E. coli per gram. It needs to be emphasized that this is a theoretical exercise based on specific
assumptions. The fact remains that toxin producing strains of E. coli were detected. ADDITIONAL RESEARCH IS
WARRANTED TO VERIFY THE TRUE NUMBERS OF TOXIN PRODUCERS AND FATE OF THESE ORGANISMS IN
BIOSOLIDS AND LAND APPLICATION."

Page 119 - Dr. Charles Gerba, Microbiologist, Dept. of Soil, Water and Environmental Science, University of Arizona.
,
"There are more than 140 different types of enteric viruses excreted by man that can find their way into domestic
sewage and biosolids ....the enteroviruses are the largest group of enteric viruses causing some of the more serious
illnesses, particularly in children."

Page 265, (Regarding a cohort study of gastrointestinal and respiratory illness in people exposed to composted
biosolids in gardening products) . . . "Approximately 1700 people took part in the study. We found no significant
association between exposure to composted biosolids and the incidence of gastrointestinal illness. HOWEVER, THERE
WAS A SIGNIFICANT ASSOCIATION BETWEEN EXPOSURE TO BIOSOLIDS AND RESPIRATORY ILLNESS."

Page 120 - "Other adenoviruses cause nose, eye, and respiratory infections. Astroviruses are also a cause of
gastroenteritis . . . " "Non-polio enteroviruses are estimated to cause 10-15 million symptomatic infections in the United
States annually ... they are associated with a broad spectrum of clinical syndromes, including aseptic meningitis,
herpangina, hand-foot-mouth disease, conjunctivitis, pleurodynia, myocarditis, poliomyelitis, rashes, neurological
disorders, and diabetes. While all age groups are affected, the most serious outcomes are in the newborns, young
children, and young adults."

Page 121 - "Children are the most severely affected by enteric viral illness."

Page 122 - "Unfortunately little research has been done on the occurrence of enteric viruses in biosolids for almost a
decade."

Page 101 - "Staphyococcus spp. identified as a "pathogen of concern" -- with note that there is little information or data.

The EPA has spent millions of dollars for a public relations campaign to promote this death and destruction on farmland,
parks, schools, as well as on home lawns and gardens. The mounted a major PR campaign attempting to discredit
retired EPA microbiologist David Lewis

HISTORY OF SLUDGE DISPOSAL AS A FERTILIZER IN PIMA COUNTY THAT LED UP TO THE EPIDEMIC
NECROTIZING FASCIITIS.

In 1983, Pima County adopted a policy endorsing the beneficial use of treated sludge on area farmlands via subsurface
injection. A program was established and design work was initiated to collect, convey and dewater the sludge in
preparation for use on non-food chain crops.

In 1983, the City of Tucson constructed a tertiary treatment plant to further treat wastewater from Pima County's Roger
Road plant for use on golf courses and other turf. Over the years mains were installed to deliver water to various
facilities on the far east side of town and in the central area. Today effluent is delivered to over 200 water consumers,
including 13 golf facilities, 25 parks and 30 schools. (old data)

In 1985, Pima County began a project to export sludge from the wastewater process for agricultural use in the Marana
area, thus lessening the burden on the nearby landfill [as required by law]. In 1987, a system for transferring sludge
from Roger Road to Ina Road was completed. As a result, neither plant sends sludge to landfills.

In 1987, The Roger Road Sludge Management Facilities were completed. Stabilized sludge could now be transferred
from the Roger Road WWTF to the Ina Road WPCF for further dewatering and thereafter, for agricultural application.
The sludge drying beds at the Roger Road WWTF were taken out of service, and the disposal of biosolids [sludge] into
local landfills ceased.

In 1986, Dr. Charles Gerba, (63) University of Arizona warned in a USEPA study document, Development of a
Qualitative Pathogen Risk Assessment Methodology for Municipal Sludge Landfilling,   that, "Information on
the fate of pathogens at existing landfills is sorely lacking. Additional laboratory and field studies are needed to
determine the degree of pathogen leaching, survival and transport in groundwater in order to estimate potential risks
from pathogens at sludge landfills with reasonable validity."

He noted organisms in bioaerosols could be transmitted by inhalation or by contact after the settled on a surfaces which
humans come in contact with. He also noted suspension of the sludge particles would be possible under windy
conditions. Gerba also note "dried sludges "may be very light and fine in texture and, therefore easily resuspended"
Exposure may be direct or aerosols may contaminate equipment. Animals and could also transport contaminated
sludge offsite.

Perhaps the most important point Gerba made was that no risk assessment can be considered complete when dealing
with microorganisms. New pathogens are recognized and the significance of well-known ones change. His main point
was that "microorganisms are subject to mutation and evolution allowing for adaptation to changes in their environment."

Even worse, many are long lived, Greba said in the EPA document, "In a sludge-soil samples from subsurface sludge
injection in Butte, MT, viruses were recovered 6 months after application (Moore et al., 1977). At a site where sludge
was applied to a forest plantation, enterviruses were detected in the soil for as long as 21 weeks after application
(Jorgensen and Lund, 1985)."

That's not all, "Natural occurring enteroviruses have been isolated from soils beneath a sludge disposal site in Denmark
(Jorgenson and Lund, 1985) and at several sites where land application of domestic sewage was practices (Hurst et al.,
1980b, Goyal et al., 1984)."

He acknowledged, "Enterviruses have been isolated from groundwater at numerous sites where land application of
wastewater is practiced (Keswick and Gerba, 1990). Stamer (1984) observed that poliovirus 1 survived in groundwater
over 100 days after leaving a septic tank."

"Moisture effects in soil systems are of major importance in bacterial decline. Kebb et al., (1978) found survival rates for
streptococcus faecalls and Salmonella typhimurium increased with increasing moisture content of the soil as several
different temperature."

Bacterial survival was much longer that EPA claimed, "Hess and Breer (1975) reported that samonellae on grass treated
with sludge could survive for a little less than 16 months in the climate of Switzerland, but most reported times are
shorter."

Gerba said, "Little information is available on survival of Campyloacter Jejuni, and no information is available on its
survival in domestic sludges or soil." Furthermore, "Information on Leptospira survival in sludges appears to be non-
existent."

[Leptospira interrogans causes leptospirosis, a usually mild febrile illness that may result in liver or kidney failure.} The
CDC states, "Humans may be infected through direct exposure to urine or fluids of parturition of infected animals, or
through exposure to contaminated water or soil. A variety of occupational and recreational activities have been
associated with leptospirosis, including farming, veterinary and abattoir work, and canoeing, kayaking, and swimming in
contaminated water."]

Risks from Pathogens

In 2003, the University of Arizona (40) even put out a press release trouting a sludge study with the statement,
"Biosolids Safe for Land Application, UA Researchers Find". Yet, the press release indirectly noted the epidemic
MRSA problem in Pima County when it stated, "Over the past 18 months questions have arisen over whether
Staphylococcus aureus, a human disease pathogen present in raw sewage, remains in treated biosolids, with the
potential for causing illness. S. aureus has an infamous reputation, and causes a wide variety of human skin and wound
infections, food poisoning, septicemia, toxic shock syndrome, pneumonia, meningitis and other infections."

In the Journal for Surface Water Quality Professionals, Stormwater, (55) November/December 2003, Dr, Edward
McGowan discussed, STAPH AUREUS ANTIBIOTIC RESISTANT MICROBES IN SLUDGE/BIOSOLIDS STORMWATER
RUNOFF (CSOS TO POTWS!)

He said, "The essence of the question was related to the survival of genetic material - hence, an
analysis on the underlying issue of surviving multidrug (antibiotic)-resistant bacteria
(MDRB). The question went something like this: "If Staphylococcus aureus are found dead,
does that mean that the problem is solved?" The corollary: Are they dead, or merely in the
viable but nonculturable state, in a starvation arrested state, or killed from a starvation but
otherwise in a recoverable state by sudden nutrient excess in the culture? Additionally, there
are issues of the reuptake of naked DNA. Recently, in discussing mobile genetic elements
(MGEs), Nielsen and others (2000) demonstrated that DNA was well protected in dead cells
and that transforming activity remained. The survival of such material was found to be up to
two years. Additionally, these and similar papers demonstrate that growing plants, via their
roots, can transfer MGEs to bacteria. The reverse has also been widely demonstrated.
Thus, nonpathogens and nonbacteria can serve as reservoirs for maintaining resistance.
Pneumococci, for example, can take up naked DNA from the environment (natural
transformation from lysed bacteria)."

On March 31, 2004, the EPA's Region 9 (42) approved ADEQ's Biosolids/Sewage Sludge Management program for
implementation in Arizona, except in Indian Country. As of March 31, 2004, ADEQ serves as the sewage sludge program
and enforcement authority in Arizona. The EPA maintains an oversight role.

While this may not seem very important, it will be very difficult to sue any entity for public health damages from exposure
to the disease organisms in sludge used as a fertilizer because state law claims it is safe and there is a state permit
under the law -- which grants immunity to the people spreading sludge as a fertilizer.

In an internet document, no date, Christopher Rensing and Chuck Gerba,(39) Department of Soil, Water and
Environmental Science, said, "The environmentally safe disposal of sewage is one of the most urgent technical and
economic problems of modern society. Arizona is a national leader in the recycling of biosolids with 95% of the biosolids
generated being used in land application" .

They say, "However, there is now concern that endotoxins and antibiotic-resistant bacteria and
endocrine disruptors in biosolids may affect near-by residents and may find their way into
groundwater. As water is a very limited and crucial resource in Arizona, these possibilities
need to be investigated.

They also say, "The use of biosolids as an agricultural land amendment is currently being questioned in the scientific
and news media causing public outcry and concern. However, very little data is currently available to address these
issues. If endotoxins or antibiotic-resistant bacteria in biosolids do represent a significant source of contamination to
Arizona water resources, this needs to be established as soon as possible."

The following summary is as true today as it was 13 years ago. See the paper.

Summary

When Congress passed the RCRA and the HSWA and gave the EPA the power to implement and enforce them, it was
to prevent other Love Canals from developing. Yet, in the fifteen years since Congress passed the RCRA and eight
years since Congress mandated the Hazardous Waste Amendments, the EPA is still allowing the uncontrolled dumping
of toxic waste. Toxic and hazardous pollutants are routinely applied to farm and ranch land. It is being disposed of
under the guise of beneficially using "domestic" sewage sludge as a fertilizer to enhance the land. However, the toxic
and hazardous pollutants (pathogens, carcinogens, heavy metals) from industrial waste in "domestic" sewage sludge
can be extremely deadly to animals and people.

The EPA's confusion between the terms non-hazardous sludge and hazardous sludge has led it to allow the States and
in some cases local municipalities to have control of the disposal of sludge without any accountability on their part.
Because the EPA believes that sewage sludge is non-hazardous, it continues to fund toxic sludge application sites which
endanger the health and safety of farmers who work them and the people who live adjacent to the sites.

This is no longer just a farmer's problem. It effects the most basic needs of each and every one of us -- our need for
uncontaminated food, clean water and clean air. Although Congress has passed the laws to control the use and
disposal of sewage sludge and given EPA a solid waste statute to implement and enforce, the EPA has not adequately
addressed the problem. Therefore, it is time that we as concerned citizens do address the problem before more damage
is done to the health of those who work on or live around these sites and those of us who consume the food raised
there.

We can not complacently set on the sidelines. We must unite to rid our environment of the danger to our health from the
pathogens, heavy metals and carcinogens found in the sludge routinely applied to farm and range land.

Closing I leave you with the warning words of Dr. Lisk (1988), "The proponents of sludge use on land claim that if sludge
is "well engineered" it is safe. The concept of a "well engineered" sludge is a myth. There is no sound scientific basis for
limiting levels of potential toxicants in sludge since we do not know the identity of most of them. Even if both of these
problems did not exist, it is extremely unlikely that any feasible monitoring and enforcement program could ensure that
application regulations are met" (P. 3).

References

Chapter 7, Deadly Microbes -- Deadly Deceit (1998)

WHAT IS NECROTIZING FASCIITIS (MRSA) AND WHY IS IT ON A RAMPAGE THROUGH TUCSON
                                           Methicillin-resistant Staphyloccocus aureus (MRSA)

Draft copy of some data to up date Chapter 7: Deadly Microbes, Deadly Deceit

Jim Bynum and Gail Bynum, Ph.D       2/14/2006                                                                     References