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

[Edo McGowan]

Dear List Serve Members,

In this entire discussion one thing has been missing.

Biosolids compost has been used since 1976 (thirty years)in public and private locations.  It has been used in Constitutional Garden for the BiCentenial; on the White House lawn (possibly that is the problem with the administration); Annapolis Capital grounds, Statue of Liberty State Park; and numerous other public places.  It has been used for 16 years as the product ComPro in the Maryland, Virgina, and DC areas in both private homes and gardens as well as public places. It has been marketed successfully in California, West Virginia, Florida and other states in large quantities for parks, highway median strips and gardens. It has been used for mine spoil reclamation and erosion control in West Virginia, Washington, and Pennsylvania.

There has never been a single documented case or evidence of any health problems in these 30 years. There is not a single article in the Medical literature or any peer review journal indicating any health risks or situations involving public health.

On the other hand, there have been numerous cases of manure contamination of foods even resulting in death.  This is because biosolids compost is regulated by both the USEPA and the various states.  Manure is not regulated. Although I enjoy organically grown foods, I am very careful as to the source and leary of locally grown products.  I would not hesitate nor have avoided eating produce grown on biosolids compost.

Eliot Epstein, PhD
Adjunct Professor of Public Health Boston University School of Public Health and Senior Scientist , Epstein Environmental Consultants, LLC.



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Rufus, in Compost Digest, Vol 28, Issue 26, you indicate----------“If new cheaper methods were really available, cities would buy them and stop working with the farm community”. 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 Koch’s postulates, Hill’s 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 NERL’s 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 agency’s 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 one’s 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---”fanatic, maniac, madman, lunatic, psychopath, loony.” How did you intend this term to be viewed? 

Edo 


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Eliot Epstein
15 Grape shot Rd.
Sharon, MA 02067
Tel: 781-784-5195
Cell: 781-603-7151