[USCC] Response to Chaney---- Open composting and disease vectors (Edo McGowan)

[Edo McGowan]

In defense of Rufus Chaney, the problem with poorly run facilities transcends composting and biosolids. Rufus is appropriately pointing out that a fly problem at one site should not be used to close all open air compost sites. As I also indicated in a previous response I believe the scenario that puts the development of disease resistance on the back of biosolids treatment and re-use is a far stretch of imagination and highly implausible. 

There are poorly run landfills, compost sites, and incinerators and there will be poorly run facilities that make biosolids into gold (oops energy). For example, a local community in my area is going through a long term battle over a pig farm. Courts and health agents are all involved and will likely end up shutting the piggery (some would same garbage dump) down. Piggeries have been around a long time and have been a long term source of neighbor complaints and here we are still going through the long and involved process of deciding who wins and who loses. 

I doubt that the composting industry, as any industry, can be expected to be self-regulating and I doubt that the creation of myriads of rule and enforcement agencies will solve the problems that neighbors have with neighbors. I have seen a well-run facility suffer at the hands of an over zealous local health agent who was eventually reined in by his board. This does not mean that local health agents should or should not have authority. This list serve could easily morph into a discussion of the democratic process and the rule of law. 

Although I am taking the time to respond, as I a read some of the postings I am beginning to better understand Al Rubin’s attitude. I would rather have Rufus’s comments on other subjects such as how we can more effectively make products that reduce Phosphorus run-off than spend time responding to concerns coming out of a group that has the single minded goal of looking to attack EPA and prove that people are dying from biosolids.   

Geoff Kuter 



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Response to Chaney---- Open composting and disease vectors 


Dear Rufus, et al., what is this about Hogwash? Here I am not even discussing pig waste from CAFOs but would be happy to do so---see below. Perhaps, however, you misunderstood where I was coming from on the flies issue, but then considering your non-medical background, that is unfortunate, but not uncommon and is certainly understandable. Some time ago we were discussing energy conversion and I think that I mentioned that this might be the wave of the future. I think you took umbrage to that. Actually three subjects---flies----antibiotic resistance----and energy-------tie together rather nicely.

Thus and by the way--------- speaking of Hogwash or pig manure, I hope you saw the recent Chicago Tribune article on converting of pig manure into crude oil. The process at U. Illinois generates as much as three times the energy used to produce it---not a bad return. Again, nothing too new here, at least in concept. Mel Gibson in the film Mad Max—Beyond the Thunderdome, worked with pig manure that powered an entire city.

The energy conversion process obviates many of the social ills and public health detractors, including smell and vector attraction, eg.,--------- flies, hence transfer of antibiotic resistance.  Further, and as an aside--- there have been some interesting papers on aerosols within hog barns and antibiotic resistant pathogens. 

As an additional item for consideration on flies, Levy noted that antibiotic resistance was transmitted from cattle, through mice gut bacteria, through flies, then into the kitchen. Thus flies can carry both pathogens and antibiotic resistance—but again that is not anything new. 

The Higgins-Murthy study put out by WERF, which I assume was part of the follow-through from the Biosolids Summit, noted that considerably more pathogens probably survive than previously thought. Accordingly then, what is coming out of a POTW as feed stock may thus carry higher loads of viable antibiotic resistant and virulent pathogens as well as just plain old pathogens. Thus the feedstock for composting may never have, in many instances, been within the limits of 503 irrespective of the operation. 

Something that the U of Illinois also seems to be doing is working with PTOW solids and their conversion to oil. Thus again obviating many of the above concerns that accompany the use of biosolids in compost or through land spreading. Good thing, eh?

Now here is a question generally thrown out, but more in your direction, Rufus. You note---------here I am quoting you--------

--------You raise the well known "not really composting" case in CA that was a subject of a cease and remove order from County and State governments. There can be no question that the situation there was in violation of many parts of 503 and CA laws, caused substantial malodor, and comprised potential runoff risks and perhaps some of the risks you discuss.---------end quote. 

Thus, Rufus, and others if they wish---how did the facility in Adalanto run so long while under the watchful eye of those crackerjack regulators and all the time in violation as you so succinctly note? Why did it take a court order to finally shut this down and in the interim where were the regulators? One might then ask------Is this case of non-regulation of not really composting then merely an isolated case or is it symptomatic of the general trend within the industry? That is a fair question and industry might ponder a well-considered answer because as you say-----this was a well known case and thus I think the general population might not make that fine distinction------ a not really composting.

Al Rubin, back in 2003, commented on the lack of EPA inspectors. Is that the problem? Not enough inspectors might explain some of this but certainly not all by any stretch of the wildest imagine. Below is an excerpt of Rubin talking about inspections of land applications, but then inspections are inspections. This is from the July 2003 meeting with Solano County.

Here I quote that transcript and this is Rubin’s response-----------How well the sites where there is land applied sewage sludge are designed, is a function of inspection. The number of sites that get inspected has been raised, but not as high as we would like to see it…. There will never be enough EPA inspectors to inspect all the fields, the rule does say it is a self implementing rule. People have to comply with the rule, if someone brings a problem to the attention of the permitting authority, and an inspector goes out and finds them in violation an enforcement action will probably be taken against that entity. It is a question of resources for the EPA to be able to do all the inspections----------end quote.

But at the Adalanto facility there were repeated issues and reported problems, but again it took the courts and not the EPA and its assistants at the local level to accomplish what should have been a simple matter, as the case was as you note….and here I quote you----------- There can be no question that the situation there was in violation of many parts of 503 and CA laws---------End quote.

As to the illness issue of composting and sewage sludge, NIOSH has written on this extensively. The issue has mainly been subsumed under respiratory issues as noted from their website----------quote--- Upper respiratory tract irritation, organic dust toxic syndrome (ODTS), asthma, bronchitis, and hypersensitivity pneumonitis are among the respiratory health problems described to occur from organic dust exposures such as those associated with composting.---------End quote. Again, there is nothing particularly new here.

Two critical and interacting issues appear to have escaped notice, however. These are 1) the transfer of mobile genetic elements and 2) the combined or synergistic effects of other irritants on the loss of protective barrier surfaces and thus interaction of pathogens. NIOSH confined the discussion to pathogens. They stated-------quote----- This document provides information, guidance, and recommendations to employers and employees working with Class B biosolids to minimize occupational risks from pathogens. It does not address other potential safety and health issues such as injuries or exposures to chemicals--------end quote. The second of these issues was brought out by the peer-reviewed papers of Gatti and Lewis. 


Because many of these pathogens also carry genetic information or mobile genetic elements that are horizontally transferable to the background flora within the human body, the risk is increased. This genetic information can carry both antibiotic resistance and virulence islands. Thus if an infection ensues, empirical antibiotic therapy may fail. Consequently, in some cases the time lost time may be critical to the point of being life threatening. Of the deaths attributed to sewage sludge, this may have been a factor and that contention has yet to be disproved.

Below is a quoted portion of an advertisement pulled off the web for a product designed and sold to commercial compost operations. The ad speaks directly to the industry, not the lay consumer. Note the mention of flies as a problem faced by the industry. This tends to belie your protest, but again, based on your background, that is unfortunate but not surprising.

-------------At present, the fundamental challenge composting facilities face is in properly aerating the piles. Oxygen starts to become limiting in compost piles within minutes of turning and the rising diesel and equipment costs makes turning compost the main management input. Frequent turning also exacerbates odor and dust issues, releasing ammonium and methane gases into the air and in the process losing valuable nutrients and organic mass. This makes for angry neighbors, NUMEROUS FLIES, and a potentially disease inducing finished product-----------End quote-----source is following URL. [http://www.emamerica.com/data/environment/composting/commercial-composting-with-em1-waste-treatment.html].

Hope the above reduces some of the confusion and that you find this enlightening.

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


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