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

Thu Jul 13 09:30:11 CDT 2006

Edo:

>From your posting, I believe that we have come to the end of our discussion 
on the safety and efficacy of biosolids and biosolids composts.  I leave you 
with the comments of Elliot Epstein that you sent into the USSC List serve 
late last night.  Elliot hit the nail on the head by emphasizing the 
enormous amounts of biosolids-based composts  that have been produced and 
successfully marketed and used with superb results without ONE DOCUMENTED 
human health impact reported.  That is the observation that forms my 
position.  It is your responsibility to go out and actually obtain peer 
reviewed data on either biosolids, biosolids composts, soils, food crops, 
etc, to sway me or any other member of this List Serve from that position.

Citing Japanese studies of pathogen resistant microbes in raw sewage just 
doesn't cut it (this from one of your earlier postings to this List Serve). 
I leave it to other members of this List Serve to continue to debate you. 
As for your solicitation to the "industry" to employ your services, my 
advice to you is don't quit your day job.

Cheers

Alan

----- Original Message ----- 
From: "Edo McGowan" <edomcgowan at earthlink.net>
To: <compost at composter.com>
Sent: Thursday, July 13, 2006 2:24 AM
Subject: [USCC] Compost Digest Vol 29, #1, et seq, continuing discussion 
between Al Rubin, Rufus

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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: Governorâ?Ts office of XXXXXX
City Mayorâ?Ts List XXXXX
NGO List XXXXXX
School Districtâ?Ts 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 agencyâ?Ts 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.

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