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

Fri Jul 21 08:45:24 CDT 2006

Ed, and all who read this,

The terms sewage sludge and biosolids are not interchangeable.  Sewage is
pre-treatment and biosolids are post treatment.  These forms are
distinguishable in the 40CFR503 regulations.  Land application of Class B
biosolids is legal, whereas land application of sewage sludge is not.
Direct incorporation of biosolids into the soil after application reduces
vector attraction and the probability of movement of biosolids in runoff.
The probability of dust from farmland where biosolids are used carrying a
significant fraction of viral components is not significant, nor is the
probability of bacterial pathogens surviving for significant periods in
aerobic environments.  

Is there a sink next to your throne in your restroom at home?  Can you be
assured that you, your family and your friends do not carry viral pathogens,
microbiological pathogens, or any other potential air born disease causing
factors? One of the most serious contributors to the spread of illness
through viral infections is the restroom in your own home.  Each time the
toilet flushes mist from the toilet fills the restroom and can cause a
significant spread of "germs".  Yet, most people leave their toothbrushes,
hair combs and brushes, and many medications in the restrooms, open to the
same contaminated air.  

I am sorry to be so graphic here, but we really need to gain some
perspective.  To be concerned about dust carrying viral and other pathogenic
entities without significant evidence of illness due to contact with the
alleged sewage allegedly carrying the viral of bacterial pathogens is the
least of the worries that should be expressed by the public.  When direct
evidence is available rather than speculation, by all means, report the
findings.  

Dave Schellinger
W. A. Callegari Environmental Center  

-----Original Message-----
From: compost-bounces at composter.com [mailto:compost-bounces at composter.com]
On Behalf Of Edo McGowan
Sent: Thursday, July 20, 2006 8:53 AM
To: compost at composter.com
Subject: [USCC] Vol 29, #9--Regulation by various agencies

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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 Virginiaâ€™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. 

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