[USCC] Compost Digest, Vol 30, Issue 12, Item #1—Response to The Rubins

[Edo McGowan]

Compost Digest, Vol 30, Issue 12, Item #1—Response to The Rubins 

Al, for starters, I certainly got a chuckle out of your post. You note---- WE ARE ALL WAITING. Evidently as the self-anointed spokesman for the group and thus perhaps de facto moderator dictating terms, allow me then to offer you a quid pro quo so that I may then begin to take YOU seriously.

I think you were head of the Water Office at EPA, yet seem not to know what is going on. You were asked a simple question as to whether EPA had followed through on the 2002 NAS/NRC report related to antibiotic resistance and off-site movement. As someone high up within EPA, someone who claims to know a lot, your silence can be taken many ways. Nonetheless, you skirted the issue completely. Either you do not know, or perhaps one might interpret it to mean that you are covering something up---is there another reason that escapes me? Your non-answer does not bode well for those listening to your dogma as their spokesman. 

Thus to make this fair, let us work out a deal right here and now and in front of your entire following. I propose that in order for me to send you a file discussing what you seem to want, you come across with some answers. Or does debate frighten you?

EPA was admonished by the 2002 report on land applied sewage sludge, as produced by the NAS/NRC, to look at both resistance and off-site movement. I have repeatedly ask the agency where this information is but without answers, including an essentially ignored FOIA. I have also asked you several times and only out side of the list-serve did you supply anything---- and that was—“forget about EPA”. That does not sound good---no answer from the agency on this critical point and then you want it forgotten? 

It has been what----- Feb 2002, until now, but then the agency would have likely been given a draft considerably before that. But let us give them the benefit of the doubt and say 4 ½ years and NOTHING? WOW what diligence in protecting the public health. Or do you feel that the WHO and the American medical establishment are just wrong about antibiotic resistance and they should---just forget it? Or perhaps you just do not understand the relationship between antibiotic resistance and escalating sickness and health care costs?


So here is my deal, you agree on this list serve to disclose in considerable detail how much progress EPA has or has not made on looking at the above noted issues per the NAS/NRC report. If they have not made any progress, you will also attempt to explain that. Further, you will discuss the relationship between sewage sludge as delivered to land application sites and the 503 requirement for pathogen numbers. That, I believe, is not to exceed ---2X 10/6th---per gram in the case of Class B. Then I would like you to discuss how that number now equates to the new WERF report showing that the viable but non-culturable remain but are not found by the standard plate counts. This is the report by Higgins and Murthy, entitled Examination of Reactivation and Regrowth of Fecal Coliforms in Centrifuges Dewatered, Anaerobically Digested Sludges. 

Thus much of what has been applied to land or delivered to composters appears to have been a fiction when compared to the requisite standard limits. The indicator bacteria are really easily killed, yet 503 allows the survival 0f 2X10/6th per gram. The Higgins-Murthy study indicates that actually several magnitudes were really there but not visible via standard lab tests. The history of this then appears to come out of Alice in Wonderland. You were the titular head of some of this, and we should forget it? If these easily killed indicators survive in such numbers, how about the survival of the more robust and more serious pathogens? And now Higgins-Murthy---and forget it?


Thus, in exchange for the above, I will provide the data you seem to want. But first we agree. By the way, as de facto moderator and spokesperson for the list-serve, just how big a file can you handle, or should I break it up into segments over several days so it does not clog the capacity of the list-serve?

I await your answer.

With ALL due respect-----------------Edo
++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++


Edo: As before, you have not offered any evidence that support your assertions. We are all waiting for any documented case of disease to be reported from the use of biosolids or biosolids composts. Until you or anyone else can report such a case, your assertions and hypotheses cannot be taken seriously.