National Sludge Alliance
NSA Public Fact Sheet 129

EPA Underplays Danger to Farmers and Public


The National Sludge Alliance (NSA) has called for an immediate ban on sludge use in any form. Based on new
research, it is evident that sludge used as a fertilizer is an eminent danger to the environment, farmer, food consumer.

The EPA scientists involved in selling sludge and their partners could not sell, give away, or pay enough to get a farmer
to use sludge, if the farmer knew the truth.  Sewage sludge carries enough pathogens, which are subject to explosive
regrowth,  to wipe out his farm and family.

While these EPA scientists have assured the farmers and regulators sludge is safe, if all the rules work, that is not the
case. In the RCRA, Congress explained  what a hazardous waste is and can do to human health. Under the Clean
Water Act, Congress explains what a toxic pollutant is and that the EPA Administrator has documented what they can
do to human health. (CWA)

Sec.1362. -

Definitions --

"The term ''toxic pollutant'' means those pollutants, or combinations of pollutants, including disease-causing agents,
which after discharge and upon exposure, ingestion, inhalation or assimilation into any organism, either directly from
the environment or indirectly by ingestion through food chains, will, on the basis of information available to the
Administrator, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions
(including malfunctions in reproduction) or physical deformations, in such organisms or their offspring."

It would appear that legislators, regulators, lawyers, scientists, and farmers who have read the definition assume that
"organisms" refers to very small creatures of the soil such as bacteria and worms. However, according to the official
definition: "Organism: [is] any form of animal or plant life."  

In effect, even legislators, regulators, lawyers, scientists and farmers are "organisms".

According to the EPA Environment Terms: "Pathogens: [are] Microorganisms (.g., bacteria, viruses, or parasites) that
can cause disease in humans, animals and plants. "  Many of the pathogens could be used for bioterrorism activities,
including food contamination.

In 1989, EPA was fairly honest when it explained the problem it was having with sludge disposal: "Wastewater treatment
processes remove pathogenic organism [and carcinogenic toxic/hazardous substances] from wastewater, not so much
by destroying them as by concentrating them in the residuals sludge streams. Because sludge volume is much smaller
than wastewater volume, concentrations of pathogens [and carcinogenic toxic/hazardous substances] on a volume
basis are much higher in sludge than in the original wastewater. The increased pathogen [and carcinogenic
toxic/hazardous substances] content of sludge makes it essential that the Agency require processing and other
procedures that minimize exposure of humans and animals to infectious organisms [and carcinogenic toxic/hazardous
substances] in sludge." (54 FR 5829)

In the 1989 preamble to part 503, EPA made it very plain that it created a list of primary pathogens based on a
literature review. The pathogenic organisms in Table IX-F.1 were included because they: "(1) are associated with a high
incidence of disease. (2) Are found in high concentrations in sewage sludge. (3) Exhibit resistance to environmental
stresses [they don't die off easily]. (4) Can be detected with available methods, and (5) exhibit low infectious does."  (58
FR 5829)

The following excerpt from a paper published by the New Mexico Environmental Department, February 1993, shows the
general state of the information available to the public at that time:

"The EPA's own research, which is stated in the preamble to the new proposed (Coded Federal Regulation Section 40,
Parts 257 and 503) sludge regulation, has documented in addition to the toxic heavy metals, a list of 25 primary
pathogens in sewage sludge.  Among these are: 1) five bacteria pathogens (Campylobacter juni, Escherichia coli,
Salmonella, Shigetla, and Vibrio Cholerae), 2) nine viruses pathogens (Entroviruses, Poliovirus, Coxsackieviruses,
Echovirus, Hepatitis A, Norwalk and Norwalk like viruses, Reovirus, and Rotavirus), 3) five helminthes pathogens
(among them are Hookworms, Tapeworms, and Nematode worms), 4) five protozoan pathogens (Toxoplasma gondii,
Balantidium, Entamoeba histolyca, Giardia lambia, and Cryptosporidium), and 5) one fungi pathogen (Aspergillus).

Most of these pathogens are very deadly to humans and animals. Although the bacteria pathogens Campylobacter
Jejuni and Escherichia coli primarily cause a relative mild case of diarrhea [this was true in the 1980s], Salmonella,
Shigetla and Vibrio cholera affect the gastrointestinal tract and can be fatal. Of the nine viruses, Entroviruses or
Picornaviruses (152 species) pathogens can cause gastrointestinal problems, respiratory problems and can also be
fatal. Poliovirus (3 species) pathogens cause inflammation of the gray matter of the spinal cord.  Coxsackievirus A (23
species), B (6species) pathogens are mostly mild, but they can cause inflammation of the heart in newborns. While
Echovirus (31 species) pathogens primarily cause inflammation of the heart, spinal cord and brain, Hepatitis A virus
pathogens cause liver problems and can lead to death. Norwalk viruses and Norwalk like virus pathogens cause mostly
diseases of the gastrointestinal tract and Rotavirus causes acute gastroenteritis.

The five Helminthes pathogens (primarily, Hookworms, Tapeworms and Nematode Worms) cause damage to vital
organs, brain, retina vessels, liver, lung and heart.  The five Protozoan pathogens cause intestinal, respiratory, and
liver problems.  The one fungi pathogen, Aspergillus, causes inflamed tissues in bronchi, lungs, aural canal, skin and
membranes of the eye, nose or urethra (Federal Register (FR), 54, P.5829 & Thomas 1988)."

According to the EPA's Office of Research and Development (ORD) (1999), if sludge with any of these pathogens in it
is applied to land or placed on a surface disposal site where humans and animals could be exposed, it is probably
being illegally applied.

There is serious implication here because EPA document references show that since 1986 it has known bacteria and
viruses can survive up to 1 year in soil. The general survival period is 2 to 12 months for bacteria and 3 to 12 months
for viruses.  

What is perhaps more serious is that the survival time on food crops and other plants.   According to EPA ORD, general
survival times for bacteria on plants are 1 to 6 months and for viruses it is 1 to 2 months.  For Helminthes ova the
survival time on plants is 1 to 5 months -- with a 2 to 7 year survival time in the soil..

As of 1999, ORD still had no data on the survival time of Giardia cysts and CRYPTOSPORIDIUM oocysts.

Exposure to pathogenic and carcinogenic toxic/hazardous substances could either be direct or indirect


touching the sewage sludge.
Walking through an area -- such as a field, forest, or reclamation area -- shortly after sewage sludge application.
Handling sludge from fields where sludge has been applied.
Inhaling microbes that become airborne (via aerosols, dust, etc) during sewage sludge spreading or by strong winds,
plowing, or cultivating the soil after application.

Consumption of pathogen-contaminated crops grown on sewage sludge-amended soil or of other food products that
have been contaminated by contact with these crops, or field workers, etc.

Consumption of pathogen contaminated milk or other food products from animals contaminated by grazing in pastures
or fed crops grown on sewage sludge-amended fields.

Ingestion of drinking water or recreational waters contaminated by runoff from nearby land application sites or by
organisms from sewage sludge migrating into ground water aquifers.

Consumption of inadequately cooked or uncooked pathogen-contaminated fish from water contaminated by runoff from
a nearby sewage sludge application site.

Contact with sewage sludge or pathogens transported away from the land application or surface disposal site by
rodents, insects, or other victors [birds & farm workers], including grazing animals and pets.

Dr. David W.K. Acheson, MD, FRCP, Associate Professor in the Department of Epidemiology and Preventive Medicine,
University of Maryland School of Medicine, says, "More than 200 known diseases are capable of being transmitted
through food. [1] Thus, no simple algorithm can be used to diagnose foodborne illness, "

Furthermore, "Foodborne disease has many different forms, involving a variety of bacteria, viruses, protozoa,
chemicals, and other types of agents that can be transmitted through consumption of food. Although foodborne illness
typically presents with gastrointestinal symptoms, including nausea, vomiting, abdominal pain, and diarrhea, it is
important to remember that these diseases can present in very different ways. Such manifestations include fever,
neurological symptoms (eg, headaches, paralysis, or paresthesia (tingling), hepatitis, or renal failure."

A recent media article mentioned that Russia had about 300 verities of bacteria in its biowarfare program. Yet, EPA only
mentions nine strains in sludge. --LSI- EPA/625/R/92/013