[USCC] Compost Digest Vol 29, #1, et seq, continuing discussion between Al Rubin, Rufus

[Edo McGowan]

Compost Digest Vol 29, #1, et seq, relative to discussion between Al Rubin, Rufus
Chaney and Edo McGowan.

Al, in answer to your last post, again I see no sense in supplying what is abundantly available in the literature. If the industry wishes to employ my services, I would consider such a proposal. Below is a response that is self-explanatory. I have left off the various list recipients since they are of no concern to the Compost readers.

To: Assembly member XXXXXX
Cc: Governor’s office of XXXXXX
City Mayor’s List XXXXX
NGO List XXXXXX
School District’s List XXXXXX

Fm: Dr Edo McGowan

Re Land application of sewer sludge and its products.

Per our continuing discussion and at the request of you and others, I am submitting this preliminary report. I have attempted without success to obtain information from the following sources. The first was the U.S. EPA through FOIA to which that agency’s cryptic and greatly delayed answer essentially failed to meet credibility. Absent that I sought answers from a recently retired senior staff member of EPA who had, as he reports, the responsibility for developing the Standards for the Use and Disposal of Sewage Sludge (Biosolids) including establishing regulatory requirements for the composting of biosolids. Additionally, I sought answers from the US Composting Council, and also a senior member of USDA who was also instrumental in establishing the Part 503.  I was able to reach all these parties and dialogue was opened, but in each case there was either an inability or unwillingness to come forth with plausible answers. These contacted senior officials were the primary authors of the 503 sludge rule and are Dr. Al Rubin formerly of EPA and Dr. Rufus Chaney, a soil scientist with the US Department of Agriculture. It is doubtful that either has a degree in medicine or a specialty in infectious or communicable disease. This deficit in their understanding is unfortunate.

In consequence, there is a growing sense that those within industry supplying information and their explanations remain excuses rather than decent reasons. Thus it appears that the underlying policy driving land application, if policy it be at all, is nothing more than the post hoc rationalizations for a series of previous inconsistencies, failed analyses, errors and missed opportunities.

The questions I proposed were as follows:

1. Prove that EPA has studied antibiotic resistance in sludge and have data showing that antibiotic resistance and its transfer via MGEs from pathogens to background organisms, thence back to man as a process is a fiction, hence sludge is not a source of antibiotic resistance. Implicit in this is the virulence islands that accrue to lysogenic viruses, e.g., Panton-Valentine Leukocidin and whether or not these genetic bits survive to transfer. 
2. Prove that EPA has demonstrated that transfer of MGEs conferring resistance are not transferred from pathogens to other organisms that can withstand temperatures of compost, and upon cooling, transfer that information back to re-blooming bacteria. 
3. Show that EPA has done health risk assessments related to pathogens that are found within sewer sludge, and thus there is no impact. 

Unfortunately, the literature does not bode well for the use of this material, especially on playing fields, this in spite of industry claims. Absent answers from the above contacts, I could in no way recommend that these products be utilized on playing fields, parks, or for road-side erosion control. As to the requirements related to the Greening of Government, my recommendation is that until there are more credible data forthcoming, the various agencies have a viable reason for refusing these products. As to continued land application in agriculture, the literature as well as the National Academy of Sciences/NRC (NAS/NRC) 2002 report raised serious health questions related to these products and these questions remain essentially unanswered. The literature shows that EPA has no pathogen risk assessments for these products.

The health hazards associated with pathogens in land-applied sewer sludge (biosolids)  have been well reported in the literature. Dozens of known enteric pathogens may be present in the untreated wastes. Sewer plants are not designed to properly treat incoming toxins or pathogens. In fact, sewer plants offer a medium for the mixing of pathogens that might otherwise seldom come together. Antibiotic resistance amongst incoming pathogens is rapidly advancing. The sewer plant augments this sharing of genetic material conferring resistance. Emerging infectious diseases are increasing, and at least one new enteric pathogen has been discovered every year over the past decade. 

Data used in the sludge regulations are greatly dated, hence many of these newer issues are not even considered. Additionally, there has been increasing demand that health risks associated with the land treatment and application be better defined. Unfortunately, the principal agency responsible for this area has included no pathogen risk assessment within the controlling regulations. Standards set for health have been set for a mere pittance of toxins that are found in sewer sludge. Additionally, pathogens are assumed to be controlled by technology based standards, not actual health risk assessments. Such standards are now old. Marker or indicator organisms employed are of limited usefulness, especially when considering the rapid emergence of new pathogens, transfer of genetic information conferring virulence, and antibiotic resistance. The lack of or limited usefulness of contained data within and upon which the regulations are set is pointed out within the NAS/NRC 2002 report on land applied sewer sludge. In essence, the NAS/NRC indicated that the data were old and had fallen considerably behind the advancement of pathogens. In addition, the NAS/NRC in that report commented on the lack of data on off-site movement as well as antibiotic resistance.  Consequently compliance with these regulations does not assure protection of public health. 

Further, the regulations covering the land application of sewer sludge (biosolids) are essentially self-implementing, consequently EPA does not necessarily review permits or implementation of the actual process but mainly relies on the industry to police itself.

A growing number of residents near these application areas are reporting illness. These illnesses can be subsumed within the broad context of the sludge syndrome. Additionally respected public water agencies are raising serious questions about contamination of ground and surface water supplies.

I have attached a fairly extensive literature search to augment this brief and preliminary report.