[USCC] Vol 28, Issue 26, Biofuels vs composting and land spreading

Sun Jul 2 23:26:13 CDT 2006

Edo:

I am sorry that I did not respond to your earlier posting in which you 
characterize that posting as a "challenge" to Rufus Chaney and me.  Well 
thank you for giving me a second chance.  I trust that Dr. Rufus Chaney and 
others on the USCC list serve who are both biosolids and composting 
professionals will also respond to to your "challenge" on the safety and 
efficacy of the recycling of biosolids to the land either as a Class B 
material or as a Class A material derived from properly managed composting 
operations.

For over 22 years, I have read allegations such as yours and in many cases I 
have responded to them.  For 21 of those years, I responded as a senior 
staff member in EPA where I had the responsibility to develop the Standards 
for the Use and Disposal of Sewage Sludge (Biosolids) including establishing 
regulatory requirements for the composting opf biosolids.

Your allegations are without any merit.  Your allegations are not new.  Avid 
readers of postings to this list serve have read commentary from Helane 
Shields, Maureen Reilly, Carolyn Snyder, and Ellen Harrison.  Their comments 
to this list serve are very similar if not identical in tone and substance 
to those of your comments.   You folks seem to network very well.  These 
comments are developed from two sophistic strategies:

1.  "The Absence of Evidence (of harm from biosolids or composted biosolids) 
is not Evidence of Absence (of harm from biosolids or composted biosolids)". 
Forget about EPA or any other regulatory body proving that biosolids or 
composting is "safe".  These institutions know that these technologies are 
safe from the simple observation that they and all of us have made:  That 
observation is that there has never been any significant verified/validated 
cases of a negative human health impact in 70 plus years of compost 
manufacture and use and close to 100 years of biosolids land application. 
You and these other commenters love to wield the request to "prove a 
negative".

2.  Allegations, scenarios, innuendos not supported by data or science. 
Sir, I challenge YOU to offer one scintilla of FIELD or PROJECT OPERATIONAL 
DATA that scientifically supports your e mail full of innuendos and "wild 
goose chasing" scenarios.  I would hazard a guess that you have never spent 
any time gathering field data or operational data on the impacts that 
biosolids and composted biosolids have on human health and the environment. 
Your antibiotic resistance/genetic transfer scenario is a creation in your 
mind without any data to support the concept in the real world of composting 
and biosolids land application.  The trace pollutant issue or as I refer to 
this hokum as "the Pollutant Du Jour" syndrome is not supported by any field 
data on either biosolids or composted biosolids.  I am sure that you will be 
sending all of us on this list serve copious amounts of data to suppoort 
your allegation that biosolids and biosolids composts have contaminated the 
nations farmlands, forests, reclaimed lands, crops, farm animals, sediments, 
lakes, rivers, and streams with metals and all sorts of organic chemicals as 
well as a host of pathogenic organisms.  WE ARE WAITING.

NO Edo:  "The ball is in your court".  It is you sir who has to 
generate/find any field/operational data and more importantly link these 
data to even begin to suppoort your allegations.  WE ARE WAITING.  In the 
mean time, others on this list serve who may now see that their legitimate 
profession of recycling nutrients and organic matter based on decades of 
research and science is under attack may want to respond to Dr. McGowan as 
well.

ZEALOT???  Edo: I agree with you.  No need to try to define the term or use 
it.  JUST SEND US THE HARD FIELD/OPERATIONAL DATA for biosolids and 
biosolids composting operations to support your rhetoric and we will not 
have to debate the term ZEALOT.

Cheers

Alan B. Rubin, Ph.D.

----- Original Message ----- 
From: "Edo McGowan" <edomcgowan at earthlink.net>
To: <compost at composter.com>
Sent: Sunday, July 02, 2006 12:54 PM
Subject: [USCC] Vol 28, Issue 26, Biofuels vs composting and land spreading

U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW
Wyndham Orlando Resort | Orlando, FL | January 21-24, 2007
The National forum for those involved in the development and expansion of 
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CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS,
EXHIBITOR INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE AVAILABLE AT THE 
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Rufus, in Compost Digest, Vol 28, Issue 26, you indicate----------â?oIf new 
cheaper methods were really available, cities would buy them and stop 
working with the farm communityâ?. I think we are seeing just that. Large 
cities are shifting to fuel conversion and the cost data show it to be more 
effective than land spreading. But again these are enterprise cost analyses 
and not more robust economic analyses.

A few issues ago (Vol. 28, #17, June 23) I mentioned two such systems, in 
the interim more are going in. I also challenged the list-serve, but 
essentially you and Al to answer some basic questions and have been watching 
for any reply. I realized that I ask some hard questions and thus would 
expect the answers to take some time.

Generally, the questions revolve about land application and composting. 
There are enough papers out there to support questions about pathogen 
survival. Further, the survival and transfer of genetic material promoting 
both virulence and antibiotic resistance warrants further analysis. The 2002 
NRC report on land application of sewer sludge admonished EPA to look at 
this and off-site movement. It is 2006 and EPA has thus far failed to 
produce this analysis, thus the question of safety remains unanswered. 
Further, EPA has apparently failed to do an adequate assessment (if it has 
done any) of pathogen risk with the use of sewer sludge as applied to land. 
It has, in the past, done some assessments on chemicals, but in reality a 
diminishingly small number out of the constantly changing and growing 
universe found in sewer sludge.

There is a compost operation just up wind of a prison in California. The 
number of workers comp claims filed by staff is impressive and these are 
directly related to health impacts. While the staff may have access to 
workers comp, the inmates do not. Thus the number of illnesses related to 
dust drift from the compost operation maybe greatly understated, considering 
the guard to inmate ratio.

In the article Emerging Infectious Determinants of Chronic Diseases, EID Vol 
12, #7, July 2006, the authors discuss the development of chronic diseases 
arising from initiation by infectious agents. Within this article and its 
discussion, several examples are provided. Once the tissue damage and change 
have occurred, reversal and tissue repair is often protracted. The 
inflammatory processes that drive some of this tissue damage may also see 
permanent changes and thus loss of function long after the offending agent 
has been removed. The interesting thing here, as pointed out by the authors, 
is that microbes can now be irrefutably linked to pathology without meeting 
Kochâ?Ts postulates, Hillâ?Ts epidemiological criteria or even the revised 
Hill-Evans logic criteria.

In this current comment, I would like to bring up the issue of antibiotic 
resistance and how vital its progression will be in the future, especially 
as we find more links between some of these chronic diseases and their 
underlying drivers. I contend that the land application of sewer sludge 
(biosolids) may be an important link between advancement of antibiotic 
resistance and its increasing resistance and community spread of disease. 
Further, I contend that antiquated standards relating to wastewater 
treatment and the land spreading of sewer sludge are major factors in this 
dilemma. Again, I would ask those in the list-serve and in particular either 
you or Al to come forth with some hard data showing that EPA has studied 
this through both pathogen assessments and review of genetic movement of 
mobile genetic elements. Absent that, I have some difficulty accepting 
claims that the activity of sewer sludge land application or composting is 
benign.

My group had requested via Freedom of Information Act (FOIA), certain data 
from the U.S. EPA on their progress dealing with biosolids and resistance. 
The EPA response, after a 6-month delay, (Feb 2005 to Aug 2005) was to 
merely direct us to a section of the NERLâ?Ts website, which contained no 
usable information. Similar results were found for other EPA web addresses.

These results seem to indicate that within the principal U.S. regulatory 
agency dealing with water quality and sewage, the understanding of 
antibiotic resistance is minimal at best. These data below are however as of 
August last year, perhaps things have changed. We confronted EPA with this 
Aug 2005 response and thus far have received no adequate explanation on the 
subject. To this day the FOIA, originally received by EPA in February 2005, 
is still unanswered. If EPA had done the work, as indicated in the 2002 NRC 
report, it would be able to produce such, especially under requirements of 
FOIA provisions. The agencyâ?Ts silence is very troubling.

RESULTS OF SEARCHING THE "ENVIRONMENTAL SCIENCES" AREA OF EPA'S WEB SITE

No matches found for transposon; 1402 files searched
No matches found for antibiotic resistance + biosolids; 1402 files searched.
No matches found for antimicrobial resistance + biosolids; 1402 files 
searched
No matches found for virulent pathogens + biosolids; 1402 files searched.
No matches found for plasmids + biosolids; 1402 files searched.
No matches found for mobile genetic elements; 1402 files searched.
No matches found for high level disinfection + biosolids; 1402 files 
searched.

RESULTS OF SEARCHING EPA'S ENTIRE WEB SITE

We have searched the entire EPA site and found the following results. You 
may also return to searching for the same terms within Environmental 
Sciences.

No matches found for high level disinfection + biosolids; 494732 files 
searched.
No matches found for plasmids + biosolids; 494732 files searched.
No matches found for transposons + biosolids; 494732 files searched.
No matches found for mobile genetic elements + biosolids; 494732 files 
searched.
No matches found for virulent pathogens + biosolids; 494732 files searched.
No matches found for antibiotic resistance + biosolids; 494732 files 
searched.
No matches found for antimicrobial resistance + biosolids; 494732 files 
searched.

RESULTS OF SEARCHING THE "EXPOSURE RESEARCH" AREA OF EPA'S WEB SITE

We have searched the area of EPA's site related to Exposure Research and 
found the following results. You may also search for the same terms across 
EPA's entire site.

No matches found for prions + biosolids; 3352 files searched.

RESULTS OF SEARCHING EPA'S ENTIRE WEB SITE WE HAVE SEARCHED THE ENTIRE EPA 
SITE AND FOUND THE FOLLOWING RESULTS. YOU MAY ALSO RETURN TO SEARCHING FOR 
THE SAME TERMS WITHIN EXPOSURE RESEARCH.

No matches found for prions + biosolids; 530969 files searched.

Rufus, as to your post when referring to Ms Reilly---relative to the 
included term ZEALOT. I had hoped to see a straight academic discussion 
without the apparent lowering of oneâ?Ts self to an attack on the person but 
merely the presented data. Perhaps I miss read the post. I did, however, 
look up the general definition of zealot through TOOLS on the computer, just 
to see if there might be some scientifically valid reason attributed to the 
term within the context of your post. Here are some of the possible 
derivatives: ZEALOT---â?fanatic, maniac, madman, lunatic, psychopath, 
loony.â? How did you intend this term to be viewed?

Edo

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