[USCC] Response to Dave & Frank re: Vol 30, Nos 1 & 3 Regulation of various agencies

[Edo McGowan]

Colleagues---the current string of conversation under the heading of Vol 29, #9--REGULATION
BY VARIOUS AGENCIES, has raised a lively discussion, which is what I had hoped for.

Dave and Frank bring up several good points. Dave notes------ THAT MANY 
CONTAMINANTS ARE DESTROYED OVER TIME IN SOILS WHERE BIOSOLIDS ARE APPLIED. 

That is a critical statement---OVER TIME---from the perspective of antibiotic resistance. As soil
microbes are continuously exposed to toxins over time, they can up-regulate or acquire 
genetic, metabolic, and cellular machinery that degrades the toxins. Pepper and Gerba have 
noted this for herbicides. Thus the levels of pharmaceuticals, heavy metals, othertoxins found 
in sewage and concentrated into sewage sludge on processing see microbes
exposed to these and thus developing resistance. But within the milieu of incoming
pathogens are those discharged by hospitals, hospice centers, nursing homes, dialysis
centers, mortuaries and many other centralized pathogen sources. Thus the mixing
of sewage provides that environment wherein a trades fair of superbugs can freely
swap information. But for the mixing within sewer plants, many of these pathogens
and potential pathogens might never come together. 

When these human pathogens and others found in sludge are then subjected to the 
rigors of soils and then mix with soil flora that have been exposed to heavy doses
of farm chemicals and heavy metals found in fertilizers, the opportunity for greater 
development and further spread of resistance is augmented. Since the application of 
sludge and compost is often surface applied, there is the opportunity for surface transport. 
To the extent that composted material containing sludge is used for erosion control, 
this results in an obvious and logical extension of the above reasoning. Further, when 
compost is used along roadways, the material may get onto the road bed and thus 
become ground into the road dust. Road dust picks up and drifts into adjacent neighborhoods. 
The movement of road dust is easily tracked 100+ yards into adjacent areas. Since the less 
economically well-off are often residents of these adjacent roadway areas, illness that might
develop are then placed on the tax base to a higher degree.

Dave goes on to note------, BUT COMPOSTED BIOSOLIDS ARE OFTEN USED MORE IN RESIDENTIAL
SETTINGS. 

With the above in mind, there may be an increased risk for adverse health effects,
but who is tracking this? With a self-regulating industry, how much effort is there
in wanting to ascertain potential illnesses? The main thrust has been in vehemently
denying health implications. Yet, for example the Sugar Creek study seems to indicate
considerable movement of land applied materials in surface water, and the worker
comp cases at the prison seem to implicate composting. But who in industry is tracking
these issues? We know that EPA, for reasons of staff limitations, has passed the
baton of enforcement to the state and locals. There are some serious problems here
and little seems to be forthcoming on these. The apologists are anything but quiet,
but offer no concrete answers, merely rhetoric. In the interim, industry continues
to operate under a cloud. Is it just a few bad actors, or is there some fundamental flaw
that needs to be corrected?

The tired old saw that is reiterated by Al is actually false and beginning to be viewed as such and now just more dogma or hype to the ignorant. Al notes---------THE BOTTOM LINE IS THAT DECADES OF USE OF BIOSOLIDS-BASED COMPOSTS HAVE NOT RESULTED IN ANY REPORTED AND DOCUMENTED HUMAN HEALTH IMPACTS.

Part of the problem is that with biosolids there is poor tracking, including health impacts. I think he probably knows this and there are enough data to show otherwise. If the same effort were applied to land applied sludge as is accorded waterborne disease outbreaks (WBDO), we might have some credible reporting. But with WBDOs, the CDC is involved. It is minimally involved in sludge---if it is even involved at all. Thus we are left with EPA and its staff is very thin with those that really understand emerging infectious disease and communicable disease. Further, EPA has punted to locals who also have little background in this, thus we are left with industry and self reporting.

For WBDOs, the primary unit of analysis is an outbreak, an individual case, with rare exception, is not considered. To be considered as a WBDO, two or more people must have reported SIMILAR illnesses. Reported cases are primary illnesses, i.e., those considered as directly connected between the patient and drinking water, not secondary cases where the person became ill through person to person contact. Reporting of primary cases can be based on actual or ESTIMATED numbers. Cases may be DEFINED BY SIGNS AND SYMPTOMS or may be confirmed by laboratory analyses or clinical specimens. Since 1989, the basis has been on strength of evidence linking water. Investigators are encouraged to make reports EVEN THOUGH DIFFICULT TO INVESTIGATE AND WHERE SOME OF THE FINDINGS MAY BE INCONCLUSIVE. While this approach tends to reduce specificity, it has helped identify new problem areas. Now if land applied sewer sludge and its byproducts had at least this process, one could say something. But if you don't ask and don't tell, all is well.

Absent an approach similar to CDC's WBDO tracking, is it any wonder that Al keeps up the old chant?


Cheers---------------------Edo