EPA Watch --- Hazardous Sewage Sludge Disposal as Fertilizer
In 1993, under court order, EPA's Office of Water released a deadly sewage sludge disposal program it likes to refer to as a regulation. The main purpose of the program was to be able to issue removal credits to polluters for land application of ten toxic and very hazardous inorganic chemicals. EPA had no concern for what the military would call collateral damage of sludge disposal (i.e., death, disease, cancer).
Hazardous sewage sludge disposal effects everyone exposed to the toxic pollutants in sludge (AKA as Biosolids) used as a fertilizer through air, water or food. Milwaukee started the first program to sell toxic contaminated Class A sludge to the public as a fertilizer in 1926. Many cities followed Milwaukee's example. The secondary aspect of the program was to protect these cities.
EPA has never had, not even one, scientific study to state without qualification that the use of sewage sludge/biosolids is safe to use as a fertilizer. In fact, EPA claims it does not have data on most of the deadly inorganic and organic chemicals, or infectious disease organisms which can be found in sludge. EPA does say that exposure to these pollutant may kill you. Yet, it asked the National Academy of Science to agree with its program as a means to change public perception about the danger of being exposed to this hazardous infectious waste sold as an unlabeled fertilizer.
For 25 years, EPA has ignored the Congressional mandate in RCRA section 4004 to find; (g)(6) methods to reclaim areas which have been used for disposal of sludge or which have been damaged by sludge."(Public Law 89-272 title III #4004 -Pl 94-580)
There is no debate. Congress and EPA says its not even safe to put sludge in a landfill! However, EPA says that if sludge can't be sold as an unlabeled Class A fertilizer to home owners, or put on food crop production land, then it must be put in a highly regulated landfill. The trick is that EPA's "Exception Quality" sludge fertilizer is too contaminated to be disposed of in a part 503 landfill referred to as a surface disposal site and most removal credits are eliminated.
Not only that, but EPA has stated, it never considered doing a risk assessment for the cancer causing metals in sludge it approved for removal credits, or any inorganic chemical not included in part 503, or for any of the organic chemicals which were not banned, no longer manufactured, or had restricted use. Cancer causing agents.
EPA has never published a risk assessment for all of the disease causing organisms in sludge because it doesn't want the public to know its Class A treatment process does not destroy many pathogens. It only makes the pathogens undetectable by standard test methods for a little while.
What exactly is sludge? Congress identifies it this way in the RCRA: The term ``sludge'' means any solid, semisolid or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water supply treatment plant, or air pollution control facility or any other such waste having similar characteristics and effects.
John Stauber, TOXIC SLUDGE IS GOOD FOR YOU looked this one up: The Harper Collins Dictionary of Environmental Science defines sludge as a "viscous, semisolid mixture of bacteria- and virus-laden organic matter, toxic metals, synthetic organic chemicals, and settled solids removed from domestic and industrial waste water at a sewage treatment plant." [10] Over 60,000 toxic substances and chemical compounds can be found in sewage sludge, and scientists are developing 700 to 1,000 new chemicals per year.
What are the characteristics and effects that concerned Congress in the RCRA?
because of its quantity, concentration, or physical, chemical, or infectious characteristics may-- (A) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or (B) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.
What causes those effects that concerned Congress in the RCRA & CWA?
``toxic pollutants, or combinations of pollutants, including disease-causing agents, which after discharge and upon exposure, ingestion, inhalation or assimilation into any organism, either directly from the environment or indirectly by ingestion through food chains, will, on the basis of information available to the Administrator, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunctions in reproduction) or physical deformations, in such organisms or their offspring.
Merriam Webster Dictionary defines organism as: 2 : an individual constituted to carry on the activities of life by means of organs separate in function but mutually dependent : a living being
A living being? I do believe that refers to the humans and animals that are being killed by this policy!
Is there any science noted in the part 503 sludge use and disposal policy?
One small scientific disclaimer for safety!
503.9(t) Pollutant is an organic substance, an inorganic substance, a combination of organic and inorganic substances, or a pathogenic organism that, after discharge and upon exposure, ingestion, inhalation, or assimilation into an organism either directly from the environment or indirectly by ingestion through the food chain, could, on the basis of information available to the Administrator of EPA, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunction in reproduction), or physical deformations in either organisms or offspring of the organisms.
Again, there is no scientific study that has ever directly addressed the toxic pollutants. Particularly infectious agents. . Nor has any scientific study stated "Class A" sludge disposed of as a fertilizer is safe. Moreover, it is unlikely that any scientists who claimed to have done a study on a few pollutants in sludge would admit he/she has ever read this disclaimer of safety.
TOXIC SUBSTANCE: A substance that can cause death, disease, behavioral abnormalities, cancer, genetic mutations, or physiological or reproductive malfunctions or physical deformities in any organism or its offspring, or a substance that can become poisonous after concentration in the food chain or in combination with other substances. http://www.epa.gov/grtlakes/lakesuperior/refer.html
WHAT CAN WE EXPECT FOR PUBLIC HEALTH?
An epidemic of Methicillin-resistant Staphylococcus aureus (MRSA) infections out side hospitals would appear to indicate that sludge has failed the public safety test. The CDC has just reported in the New England Journal of Medicine that from 2001 through 2002, 1647 cases of community-acquired MRSA infection were reported. That is from just three places, Baltimore and Atlanta and from hospital-laboratory-based sentinel surveillance of 12 hospitals in Minnesota. http://content.nejm.org/cgi/content/short/352/14/1436
Besides the health and death risks associated with hazardous sewage sludge disposal as a fertilizer, there is a legal risk in many states if anyone complains that their food has been contaminated by the toxic pollutants. They could be sued under the food slander laws, unless they have the scientific data to prove their point.
Don't expect help from the Health Departments. The Environmental Departments, who approve sludge disposal as a fertilizer, have more statutory power than the Health Departments.
On the other hand, how do you explains some state health departments who actually handle the permitting on hazardous sludge open dump sites based on EPA policy?
What can you do to stop hazardous sludge dumping on your food and your yard?