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Ask White House & EPA to Ban Land Application of Sewage Sludge Biosolids

11-30-09 GRU biosolidsURGENT: sludge ban petition/please sign  There is an excerpt from and link to an article by David Lewis titled Institutional Researcher Misconduct: An Honest Researcher's Worst Nightmare that will put this petition into context. From the intro: Scientists have implicated environmental pollutants and pediatric vaccines as possible causes behind the rising incidence of autism spectrum disorders (ASDs). Some vaccines may also increase the risks associated with environmental pollutants linked to autism. Government organizations and the pharmaceutical industry, however, are highly motivated to predetermine the outcomes in this area of research by funding scientists to support government policies and industry practices.

By David Lewis and Caroline Snyder

Dear friends,

To pressure EPA to address the potential for complex mixtures of neurotoxic pollutants in biosolids to trigger neurological effects associated with autism, please take a moment to sign the White House petition  posted by Dr. Caroline Snyder. I am currently writing an article on this subject with faculty at Virginia Tech, and would like to refer to the White House petition if we can get at least a few thousand signatures.

Scientists investigating the role environmental pollutants play in triggering autism in genetically susceptible children are focused on traces of a few heavy metals and organic chemicals from automobiles, coal-fired plants, agricultural practices and other sources. These pollutants are typically present in air, water, and food products in the low parts-per-trillion (ppt) range. At the same time, every large municipality throughout the industrialized world permits chemical wastes to be discharged into sewer systems where complex mixtures containing hundreds of thousands of different kinds of fat-soluble heavy metals and toxic organic molecules are concentrated in sewage sludge.

Most sewage sludge is simply treated with lime to reduce pathogen levels and odors and then spread on farms, forests, golf-courses, school playgrounds and other public and private lands as "biosolids." The same heavy metals and toxic organic chemicals linked to autism in traditional environmental studies are present in biosolids at high parts-per-million (ppm) levels, i.e., more than a million times more concentrated. To suppress valid, independent research on the effects of biosolids, EPA established a network of land-grant universities to publish thousands of peer-reviewed scientific articles to support EPA's biosolids regulations and attack scientists such as myself who document adverse effects. Please see my Autism Science Digest article attached to this email.

 Caroline and I would be happy to answer any questions you may have. She can be contacted at cgsnyder@post.harvard.edu and www.sludgefacts.org.

URGENT: sludge ban petition/please sign

Lisa  Jackson will be replaced by a new EPA administrator.  This is a golden opportunity for us  to use  We The People,  the  Whitehouse Petition Web site, to request that Obama work with the new EPA Administrator to ban the land application of sewage sludge.  I have drafted a petition.  

All you need do is go to the URL below,  create a pass word and sign the petition and then ask  family, colleagues, and friends, to sign it, as well.  Use Facebook and Twitter to get more signatures.   Once we have 150 signatures, the petition will be posted on the  We the People web page for others to see, and we will get a lot more signatures. 

Thank you for starting the New Year with renewed efforts to protect human health and the environment.

Caroline Scientists have implicated environmental pollutants and pediatric vaccines as possible causes behind the rising incidence of autism spectrum disorders (ASDs). Some vaccines may also increase the risks associated with environmental pollutants linked to autism. Government organizations and the pharmaceutical industry, however, are highly motivated to predetermine the outcomes in this area of research by funding scientists to support government policies and industry practices. Ironically, honest scientists who stand in the way can find themselves charged with research misconduct by institutions seeking to discredit their work. Institutional research misconduct, therefore, involves two powerful forces: supporting institutional policies and practices through acts of fraud, andusing false allegations of research fraud to eliminate opponents. Science has never offered greater hope than it does now for treating and preventing autism, butthat hope diminishes as government and industry surreptitiously mobilize vast resources to protect their own interests.

Important cases related to autism research Table 1 lists four apparent cases (described in more detail below) of institutional research misconduct related directly or indirectly to autism research. (Read the full text of Institutional Researcher Misconduct: An Honest Researcher's Worst Nightmare.)

Comments

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Conventional sewage treatment plants produce sludge in the primary settlement stage of treatment and a secondary, aerobic sludge in final settlement tank after the biozone. This sludege is a biohazard but is being spread on land in the UK - land that you walk on.

A careful reading of 40 CFR Part 503--including the preamble--indicates that Mr. Rehder is mistaken. Class B biosolids can be applied to the surface and do not need to be tilled into the ground. In fact, more than half of the nation's Class B sludge is surface-applied. And not just to grow feed, but also food for human consumption. There is a 30 day waiting period after pastures have been surface applied, before animals are permitted back, but cattle, and sheep consume a lot of dirt with their forage; so on sludged pastures they do no only ingest plants covered with sludge --the stuff is very sticky and not removed by rain-- but they also they ingest the actual sludge.

All human food crops are permitted to be grown on sludged land. The only rule is that crops whose edible portion is under the ground ( carrots, beets, etc) cannot be planted until until after a certain waiting period. The waiting period for other crops is shorter.

So the 503s permit all direct--to-the- consumer food crops -- whether it is milk, meat, lettuce, carrots, oranges, --to be grown on sludged land. In this case, it is Mr. Rehder who is presenting false statements.

Caroline Snyder-

Mr. Rehder is mistaken about land application practices in the United states, and the requirements of the 503 Sludge Rule. He asserts that the rule requires "a time-temperature threshold" be reached for all Class A biosolids, and that Class B biosolids "must be applied at least 3 inches under the ground surface on agricultural fields not used for the production of direct-to-consumer food crops." [How does someone apply biosolids several inches under the ground surface?]


Class A and Class B refers only to indicator pathogen levels, and nothing else. EPA's "Plain English Guide to Part 503 Rule" [1], p. 37, Table 2-5, describes "Alternative 1", the most common method used for meeting 503 Class B requirements, as simply: "Test for fecal coliform ... at time of use or disposal." On the following page (p. 38), Figure 2-4 outlines the 503 requirements for applying Class B biosolids to farmland for growing agricultural crops.

I don't know where Mr. Rehder got the information; however, municipalities and biosolids industry trade associations are notorious for spreading the kind of disinformation about the 503 rule contained in his comments. People should always go to EPA's official website and compare their information with the 503 rule itself.

See also my peer-reviewed study published at www.biomedcentral.com/1471-2458/2/11. It states: "Class B biosolids, the most common form of processed sewage sludges used in agriculture, are treated to reduce levels of pathogens by various processes including anaerobic digestion and pH elevation (lime stabilization)." In addition to being externally peer-reviewed by the journal, this paper was also internally peer-reviewed by both EPA's Office of Research & Development - where I worked as a research microbiologist - and by EPA's Office of Water, which developed the 503 sludge rule. It was also approved by EPA's Pathogens Equivalency Committee, which deals specifically with Class A v. Class B issues.


In the study, we investigated adverse health effects reported at ten land application sites in the US and Canada. All except for one were limed sewage sludge applied to land surface, mostly agricultural lands. One site was Class A, which was produced by adding lime to sewage sludge until the composition was 90% lime. (No heat-time exposure requirements.) For a more detailed discussion of Class A versus Class B, see our paper in Environmental Health Perspectives [2], which was also reviewed by EPA's Pathogens Equivalency Committee.


[1] U.S. EPA. Plain English Guide to Part 503 Rule.Available at http://water.epa.gov/scitech/wastetech/biosolids/upload/2002_06_28_mtb_biosolids_503pe_503pe_2.pdf


[2] Gattie, D.K. and D. L. Lewis. 2004. A high-level disinfection standard for land-applied sewage sludge (biosolids). Environ. Health Perspect. 112:126-31.


Ryan Rehder

While providing more detail I can't see how what you are saying contradicts the claims of this article.

The statement that "most sewage sludge is simply treated with lime to reduce pathogen levels and odors and then spread on farms, forests, golf-courses, school playgrounds and other public and private lands as "biosolids."" is simply false.

In fact, the EPAs 503 rules regarding land application of biosolids requires a time-temperature threshold to be reached to achieve class A status. Class A biosolids are the only biosolids that are permitted to be applied to the ground surface. All other biosolids must meet class B requirements and then must be applied at least 3 inches under the ground surface on agricultural fields not used for the production of direct-to-consumer food crops.

I am not advocating for nor in opposition of the point of this article. I am simply pointing out that presenting false statements minimizes the impact of any argument.

Phelps and Buseck (2006) tested for mercury in soils at Yellowstone National Park. They found an average level of 0.020 parts per million with a high level of 0.050 parts per million (see reference 1).

Early et al (2008) tested for mercury in biosolids mixed half and half with yard compost at the landfill at Alachua County, Florida. The middle of the levels was 0.924 parts per million with a range of levels from 0.368 to 5.320 parts per million (see reference 2).

FDA and CDC guess that the mercury levels in Thimerosal preserved vaccines are 50 parts per million. This guess is two hundred and fifty times the liquid D009 mercury hazardous waste levels (see reference 3).

So just as D009 liquid mercury hazardous waste (all of the unused Thimerosal preserved flu vaccines) should not be injected into human beings, biosolids should not be placed into our croplands or other environmental damaging locations. Please sign the petition.

Reference 1: “Background levels of mercury in Yellowstone soils are 20 ppb.” http://economicgeology.org/content/75/5/730.abstract?maxtoshow=&HITS=10&hits=10&RESULTFORMAT=&fulltext=background+levels+of+mercury+in+soil&andorexactfulltext=and&searchid=1&FIRSTINDEX=0&resourcetype=HWCIT


Reference 2: “Mercury concentrations in compost samples from Palm Beach County, Florida, consisting of a 1:1 mixture of biosolids and yard waste, ranged from 368 to 5320 μg kg-1 with a geometric mean of 924 μg kg-1.” http://wmr.sagepub.com/content/17/4/305.abstract?maxtoshow=&HITS=10&hits=10&RESULTFORMAT=&andorexacttitle=and&andorexacttitleabs=and&fulltext=mercury+levels+in+biosolids&andorexactfulltext=and&searchid=1&FIRSTINDEX=0&resourcetype=HWCIT

Reference 3: http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol27/xml/CFR-2012-title40-vol27-sec261-24.xml

I hope everyone reads the full article!! it's excellent. LInk here:

http://www.rescuepost.com/files/lewis-d-asd-april-2012-1.pdf

I've signed the petition, and I also want to thank Dr. David Lewis, a scientist with integrity and courage.

This petition is restricted to US residents and I hope as many of you as possible will find time to sign this.

In the UK, where I live, raw sewage sludge is presently added to animal waste and sprayed onto the fields as 'slurry'. This has been tentatively linked to a number of illnesses, including ME, but as far as I know, research into any possible ill effects, has not been carried out.

Dr Lewis and his colleagues have highlighted some very important concerns. Please support them.

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