[USCC] Response to Reilly regarding Adelanto site

[David Schellinger]

Rufus, Maureen,
In addition to what Rufus points out about antibacterial chemicals in
biosolids, most antibacterial components only have antibacterial properties
when used in concentrated forms, but may become food for microorganisms in
diluted concentrations.  Take honey for instance.  In concentrated form it
has antibacterial properties and because of the high concentration of sugars
that produce osmotic conditions beyond which microorganisms can exist.  But
we all know that sugars are a great source of readily available carbon in
diluted forms.  The same is true for soaps that contain hydrolyzed fatty
acids that are impregnated with salts.  The same may be true also for most
organic chemicals such as alcohols.

Dave Schellinger
W. A. Callegari Environmental Center 

-----Original Message-----
From: compost-bounces at composter.com [mailto:compost-bounces at composter.com]
On Behalf Of Rufus Chaney
Sent: Wednesday, August 23, 2006 12:15 PM
To: compost at composter.com
Subject: [USCC] Response to Reilly regarding Adelanto site

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Dear Ms. Reilly:

I was confused about the site you named and thought it was the case from
years ago in which a massive pile of biosolids was accumulated by a
contractor on an Indian Reservation site in CA. At that site there may have
been some composting, but it was eventually a massive pile and was the
subject of a stop action order and all biosolids were eventually removed.
Those were Class B. And illegal. But the regulation of biosolids on Indian
lands was a legal complication that took some time to work out.

So I looked up the Adelanto site on the web. I found a report from the CA
Dept. Health Services, Environmental Health Investigations Branch at
http://cc.msnscache.com/cache.aspx?q=3878638985579&lang=en-US&mkt=en-US&FORM
=CVRE3
     This letter says the site was in compliance with 503, but that 503 does
not regulate gaseous emissions of composting sites. They note apparent
violation of particulate dust (PM10) in excess of CA limits to an
immediately off site location but noted that populations were distant from
the edge of the composting site.

>From this letter, I suspect you have been in contact with anti-biosolids
forces in southern CA; the description of the problem in the official letter
is different from your description. Most of the singnificant exposures would
have been to workers, not to the neighborhood. It was a windrow composting
operation, and dusty. Because of dry air in CA, windrows may need to be
watered to maintain optimum water content for composting, and for dust
control. Well managed sites have water trucks working day and night to keep
down dust emissions. During windrow composting operations, pathogens remain
for some time because multiple turnings while the piles exceed 55C are
required to achieve Class A pathogen reduction. During an official visit,
malodor was noted when piles were turned, but not severe malodors.

I have no special information or comment about this site and their
operations. They were visited repeatedly by the County/State Health
Department, and EPA Regional staff were kept informed. If they are in
violation of their requirements, regulatory actions will or have occurred.
The official letter I note above was from May 5, 2005. 

-----------------------------------------
Now, I'd like to address the point you have noted about extreme risk of
lethal infections at Hospitals in the US/North America which you suggest
result from dispersal of anti-bacterial compounds in biosolids/compost
products. And this connects with Mr. McGowans's comments about
anti-bacterial compounds in biosolids.

If there is a public health problem from use of anti-bacterial compounds in
consumer products, where is the highest exposure and selection of resistant
organisms occurring? Surely at the point where concentrations are highest,
in our homes and on our bodies. When the anti-bacterials are diluted in
wastewater and either biodegraded, metabolized and residues partially
accumulated in biosolids, the concentrations are very much lower than in the
consumer products.

So, I would reason that if there is a significant risk from use of
anti-bacterials in consumer products, the proper action would be to seek the
termination of such use. Not to claim risks from anti-bacterial residues in
biosolids utilization and composting. When chemicals used in industry or
consumer products are found to be unacceptable in the environment, they are
prohibited (DDT, PCBs, etc.). Trace levels in biosolids were seldom the
important source of exposure which required action, although highly
contaminated biosolids were identified and land applications termination
until pretreatment or termination of the chemical use improved biosolids
quality. Some dangerous chemicals are used in industry which require on site
destruction without discharge to the sewers. 

So please don't yell at POTW/biosolids folks or composters about traces of
anti-bacterials in composts and biosolids, levels which are readily
biodegraded in the soil environment. Focus your attention on production and
use of consumer products which contain these compounds. If these compounds
do increase the risk of infections in the general population, FDA will
eventually act. 

--------------------------------------
Now, what about your claim of an adverse effect of biosolids related to
hospitals and infections? The concern about hospital infections is well
known. Again, the selection of resistant organisms seems to be related to
the concentration of organisms in hospitals, and to the intense use of
anti-bacterials and bactericidal agents in hospitals. Perhaps incomplete
treatments with bactericidal agents causes selection of resistant organisms.
And susceptible hosts in the hospital help maintain colonies within
hospitals. 

If you follow the logic I have summarized, you should see that hospital
infections and deaths are simply not a problem caused by biosolids or
composts. The problem you raise is a difficult social issue; some industries
manufacture and sell anti-bacterial products for home use; advertizements
abound even for sprays to kill airborne bacteria in the home. Both organic
anti-bacterials and general bactericidal products are commonly used to
remove microbial contaminants in the kitchen and bathroom. Citizens need to
be able to clean the surfaces in their homes to remove microbial
contamination, so at least some of these will continue in use. If chlorox
type cleaner/killers are to be preferred to organic chemicals which leave
residues for human exposures, perhaps you can focus on that message rather
than your claims that biosolids and composts are dangerous because they
contain traces of anti-bacterial compounds.

In my view, this round of discussion of anti-bacterial compounds in
biosolids and composts followed the publication of a paper in Environmental
Science and Technology and a well crafted press release about triclocarban..
They provided no evidence that the residue of the anti-bacterial in
biosolids could comprise a risk, just that it was present. They did not
summarize evidence that the compound is readily biodegraded in aerobic soils
even though it persisted during anaerobic digestion, a result seen with
other xenobiotics and oils. And they failed to note the high exposures which
occur at the point of use in the home. I argue that such claims are
inappropriate at this stage of research, but such language is important to
researchers who are seeking more $ to continue to study trace levels of
consumer products in the general environment.

Heidler, J.; Sapkota, A.; Halden, R.U. 2006. Partitioning, Persistence, and
Accumulation in Digested Sludge of the Topical Antiseptic Triclocarban
during Wastewater Treatment. Environ. Sci. Technol. 40(11):3634-3639.
     "The topical antiseptic agent triclocarban (TCC) is a common additive
in many antimicrobial household consumables, including soaps and other
personal care products. Long-term usage of the mass-produced compound and a
lack of understanding of its fate during sewage treatment motivated the
present mass balance analysis conducted at a typical U.S. activated sludge
wastewater treatment plant featuring a design capacity of 680 million liters
per day. Using automated samplers and grab sampling, the mass of TCC
contained in influent, effluent, and digested sludge was monitored by
isotope dilution liquid chromatography (tandem) mass spectrometry. The
average mass of TCC (mean ( standard deviation) entering and exiting the
plant in influent (6.1 ( 2.0 íg/L) and effluent (0.17 ( 0.03 íg/L) was
3737(694 and 127(6 g/d, respectively, indicating an aqueous-phase removal
efficiency of 97 ( 1%. Tertiary treatment by chlorination and sand
filtration provided no detectable benefit to the overall removal. Due to
strong sorption of TCC to wastewater particulate matter (78 ( 11% sorbed),
the majority of the TCC mass was sequestered into sludge in the primary and
secondary clarifiers of the plant. Anaerobic digestion for 19 days did not
promote TCC transformation, resulting in an accumulation of the antiseptic
compound in dewatered, digested municipal sludge to levels of 51 ( 15 mg/kg
dry weight (2815 ( 917 g/d). In addition to the biocide mass passing through
the plant contained in the effluent (3 ( 1%), 76 ( 30% of the TCC input
entering the plant underwent no net transformation and instead partitioned
into and accumulated in municipal sludge. Based on the rate of beneficial
reuse of sludge produced by this facility (95%), which exceeds the national
average (63%), study results suggest that approximately three-quarters of
the mass of TCC disposed of by consumers in the sewershed of the plant
ultimately is released into the environment by application of municipal
sludge (biosolids) on land used in part for agriculture."

Regards,

Rufus Chaney
Beltsville, MD
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