Re: [USCC] Compost Digest, Vol 30, Issue 12, Item #1â?"Response to The Rubins

[The Rubins]

Edo:

For clarification, I was the lead technical staff person for the development 
of the Part 503 Standards and I served in that capacity from 1984-2005.  I 
did not set policy; that was for the higher GS grades and the political 
appointees well above me.  However, I did offer them my advice in the 
establishment of those policies relating to the management of biosolids. So 
yes, I was in position to be able to respond to your assertions.

As for the NRC/NAS Report:  The bottom line of this report states:  "There 
is no evidence that the Part 503 Standards have failed to protect human 
health from the land application of biosolids."  Further, this bottom line 
states:  However, there are still uncertainties associated with this 
practice and that further studies should be undertaken to reduce these 
uncertainties.  Notice that the NRC/NAS Report did not recommend a ban on 
biosolids land application.  In speaking to members of the NRC/NAS committee 
that offered the report, many said:  "If we felt that there was a threat to 
public health from the land application of biosolids, we would have 
recommended a moratorium on the practice."

Likewise, USEPA and all 50 States allow and regulate the land application of 
biosolids.  If the danger from this practice that you portray is so great, 
wouldn't at least one state have banned biosolids land application and/or 
biosolids composting by now??  Oh wait, USEPA, all 50 States, academia, 
USDA, the wastewater treatment and composting industry, all must be part of 
a conspiracy to cover up the horrors that you describe so that the public's 
health can be placed in jeopardy!!!!  This "conspiracy theory" is right up 
there with fluoride in the drinking water and the assisination of JFK.

What you really can't handle is:  For the past 70 + years, biosolids has 
been land applied and composted and you and your colleagues cannot document 
one case where negative human health impacts have occurred.  I don't think 
you can make the same case for the land application of animal manure 
(Walkerton, Ontario for instance).  Edo, it must pain you to realize that 
every day, biosolids is being land applied and composted and that composted 
products are being effectively used all over the US without any documented 
reports of human health impacts.  Are the local authorities  (health 
agencies) who are the "first responders" to any reported health impacts also 
part of your conspiracy?  Please tell us why the members of this list serve 
should take your rhetoric seriously??

As for USEPA executing what the NRC/NAS Report requested, the plain fact is 
that USEPA still places biosolids land application at the low end of the 
totum pole with respect to risk.  The reason for this position is contained 
in the above paragraph.  EPA's diminished research budget and the time that 
it will take to execute the requested research by the NRC/NAS reflects the 
low risk ranking.  With respect to political considerations, USEPA cannot 
state this but take it from me, it is true!!!  USEPA and the States feel 
comfortable in allowing biosolids land application with the current 
standards in place and rightfully so.  Further research is "nice" but it is 
highly unlikely that results from additional research will change this 
paradigm.

Finally, to other members of this list serve, I would expect that you are 
not losing any sleep over Edo's preposterous assertions.  After all, you 
would not continue to produce and market compost if you really believed that 
a 70+ year track record of safety was false.  My advise to you composting 
"knights and ladies" is SLEEP WELL.

And so Edo, we all are still waiting for your evidence from a real 
composting or biosolids land application project that supports your 
rhetoric.  As for the size of the file that you threaten us with, please 
check with the Administrator of this list serve as to the size of the file 
that can be transmitted.

When I return on September 9, I expect that many on this list serve will 
express their opinions on this issue.  Thanks and "Hats Off" to Frank, Dave 
Schellinger, Rufus Chaney, and Tim Evans who have introduced a modicum of 
sanity to these discussions in recent postings.

Cheers

Alan

---- Original Message ----- 
From: "Edo McGowan" <edomcgowan at earthlink.net>
To: <compost at composter.com>
Sent: Friday, August 11, 2006 10:48 PM
Subject: [USCC] Compost Digest, Vol 30, Issue 12, Item #1â?"Response to The 
Rubins


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Compost Digest, Vol 30, Issue 12, Item #1â?"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 wasâ?"â?oforget about EPAâ?. 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.


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