[USCC] The 2002 NAS/NRC report on biosolids

[C. Snyder]

This is in response to Dr. Rubin's recent  postings about the need to
"show him dead bodies" linked to the land application of municipal 
sewage sludge.

The request is bizarre. Does EPA have to wait until there are dead
bodies, before it tightens its regulations?  Actually, two of the deaths
linked to land application( and hundreds of cattle deaths) HAVE been
documented in the peer reviewed scientific literature. As have many of
the sludge-related illnesses.

The sentence in the 2002 NAS report, he and other defenders of the 
current policies like to repeat ad nauseam  about "no documented 
evidence" should never have been included in the report  1.) because by 
the time the report came out, there WAS documented evidence, which all 
the panel members had in their posession and which was listed in the 
pre-publication copy; and  2) for decades  EPA and the industry bent 
over backwards NOT to thoroughly  investigate and document the hundreds 
of  complaints by sludge-exposed individuals.

Contrary to  Dr. Rubin's claim,  the "no documented evidence" sentence
is NOT "the bottom line" of the 2002 NAS report;  the overriding thesis 
of the 269-page NAS report is that the science and risk assessments
underlying the 503s are either non- existent or out-dated, and that this
land applied contaminated waste material is so unpredictable and 
complex, that it is not possible to accurately assess its risks to human 
health, that a great deal more research is needed before the practice 
can be declared safe, and that there is an urgent need for health studies.

Consequently, EPA no longer promotes the land application of sewage
sludge; in 2003, Dr. Rubin's former boss, Paul Gilman, said on CBS 
evening  news that his agency can no longer guarantee the safety of land
application and "that the whole issue needs to be revisited."

Caroline Snyder