[USCC] Vol 29, #9--Regulation by various agencies

[Edo McGowan]

Evidence for the absence of control in land applied biosolids 

The facade is cracking and the new clothes of the king are in tatters.

Within this list-serve we have discussed the land application of biosolids and their products. Within those discussions have been debates on how well the 503 regs have worked, whether or not EPA had the requisite capacity to deal with pathogens and passing the baton of regulatory control to the local jurisdictions. The NAS/NRC 2002 report on the land application of sewer sludge admonished EPA that it needed to do more study, that its basis for 503 was flawed. The EPA Inspector General reiterated these concerns. Cornell came out with a telling report, yet the spin masters of sludge continue as tailors to the king. The excerpt below from the Lynchburg Virginia News and Advance merely amplifies this--note reference to biosolids.

The Sugar Creek study, a peer reviewed paper demonstrated that land applied sewer sludge (aka biosolids) does not stay where it is placed and the pathogens do move. Gerba in other contexts demonstrated that once within marine/estuary sediments, the sewage derived viruses had long survival and that even the fragments from some of virons were still infective. Dust is a vehicle for pathogen movement. Gerba in unpublished studies has noted contamination spread throughout a home. Rusin and Gerba published on finger to mouth transfer of pathogens. Workers at composting operations have reported similar symptoms to those reported by neighbors within areas of land applied sewer sludge. Monday morning fever is a classically studied condition. The literature is replete with other examples.

The State of California, through its Worker Comp program is now processing several adverse health claims by prison staff who work down wind from a sewer sludge composting operation. Since the prison guard to inmate ratio usually shows an abundance of inmates to guards, there is thus reason to suspect that several of the inmates are also suffering from similar illnesses. Because it is within the perview of Worker Comp, the files are not available. I have, however, discussed some of this with attorneys. These are not just ANECDOTAL reportings.

I have shown in previous postings that the EPA enforcement division was highly stressed and essentially incapable of adequate monitoring. Again, it must be remembered that the EPA Inspector General came to this same conclusion. The agency actually does not regulate as much as it depends on industry to self-regulate. This situation has seen an absence of record keeping and thus the "absence of illnesses" has been a self-fulfilling prophecy based on the lack of adequate policy. 

Until the industry begins to help police itself in a very serious way, it will suffer being tarred with the same brush as those bad apples within its midst. In the long run the spin doctors who claim all is well will help lead the industry down the primrose path into ruin. Science will prevail over spin. Science does not flow from authority and dogma does not direct science in spite what some in the spin industry may think.

>From the Lynchburg Virginia 
News and Advance 

Monday, July 17, 2006 


State environmental officials are studying the sources of pollution in Lynchburg-area waterways. Officials with the Department of Environmental Quality, the Department of Conservation and Recreation, and Virginia’s Region 2000-Local Government Council held a public meeting at Lynchburg College on Monday night to share preliminary results of a yearlong water quality study to be completed in early 2007. 


So far, the study has found a variety of ways the pollutant enters the waterways, including through: pet, livestock and wildlife waste; combined sewer overflows; biosolids and broken septic systems.