From : HShields <hshields@worldpath.net>
Sent : Saturday, January 3, 2004 11:37 PM
To : "COMPOSTING COUNCIL" <compost@compostingcouncil.org>
Subject : TO COMPOSTING COUNCIL - RENAMING CLASS A SEWAGE SLUDGE "COMPOST"
As you all  must know by now, the US EPA  and waste industry are  proposing to lump  Class A sewage sludge in with your "green and clean" composts, and call them all     
 
The problem is that sewage sludge composts contain significant concentrations of toxic metals, radionuclides and hazardous industrial chemicals.   In addition to commercial and industrial wastes, official EPA policy is to dispose of landfill leachates and treated Superfund wastes in local sewage treatment plants where the wastewater treatment process partitions the chemicals to the sewage sludge.
 
The EPA and waste industry have been trying for years to confuse the public so people won't realize all the euphemisms ( "biosolids", "wastewater residuals", "condensed biologic solids", etc.) are actually sewage sludge as defined in 40 CFR part 503.9(w):  "Sewage sludge is solid, semi-solid, or liquid residue generated
during the treatment of domestic sewage in a treatment works."
 
Class A sludges must meet pathogen levels of either a fecal coliform limit of less than 1,000 fecal coliform/g dry weight of solids or a measure of less than 3 salmonella/4 g dry weight of solids.     However,  US EPA acknowledges significant problems with pathogen regrowth in Class A sewage sludge --  particulary in cool, damp climates --  because of the absence of competing microorganisms.  Compounding the problem, the EPA weakened sludge testing requirements in 1999.    
 
  Furthermore, scientists and microbiologists have been telling the EPA for years that Salmonella sp. and fecal coliform are not adequate pathogen indicators because they are vegetative bacteria that are highly susceptible to both chemical disinfection and heat disinfection.    Suggestions for more appropriate and hardier sludge pathogen indicators include Adenoviruses, Coliphage, Clostridium perfringens, Enterococci, Enteroviruses, and Escherichia coli.
 
So why should we care if Class A sewage sludge is lumped together with  clean and green composts which are free of human pathogens and industrial wastes?    Because there are certain places where it is inappropriate to use Class A sewage sludge --- such as on ballfields and playgrounds where children will be exposed (dermal and inhalation, plus all kids eat dirt -- and PICA kids eat lots of dirt !).   Class A sewage sludge does not belong in home vegetable gardens - once again, dermal and inhalation exposure, plus sludge pollutants can be taken up by plants  and pose an ingestion risk.    Also, Class A sludge composts emit endotoxins which pose a respiratory/health risk.
 
USDA regulations prohibit the use of sewage sludge in organic gardening.   How will  organic gardeners  know the "compost" is sludge-derived without appropriate labeling?   And let's not forget, the use of "pathogen-free" Class A sludge caused a Staphylococcus Aureus infection in one of your own members: 
 

 
 
>>> wquinn@anla.org 08/06/02 03:58PM >>>
I got a Staphylococcus aureus infection of my skin from handling composted
sewage sludge ("biosolids") at my home, so that's enough research for me.  "
 
     I suspect one of the reasons the waste industry and EPA want to hide Class A sewage sludge in "compost" is because so many sewage treatment facilities around the country are upgrading from producing Class B sewage sludge (toxic, pathogenic, nasty) to producing the less controversial Class A sludge.   So the problem is,  Class A sludge derived products are  rapidly becoming a glut on the market -- so there is no market -- no-one wants them.
 
    I enjoy your chat room and perceive that a majority of members mean yard trimmings, clean wood, vegetative matter, paper and manure when discussing "compost".   It would be a shame to   see the waste industry and EPA contaminate both the concept and the "product" with toxic sewage sludge.
 
 
Helane Shields, PO Box 1133, Alton, NH 03809  
 
    

----- Original Message -----
From: HShields
Sent: Friday, January 02, 2004 8:32 PM
Subject: send email to composting council excoriating EPA renaming Class A sewage sludge "compost"

 
``Greening the Government Through Waste
Prevention, Recycling, and Federal Acquisition.'' Specifically, EPA is
proposing to revise the current compost designation to include compost
made from manure or biosolids, and designate fertilizers made from
recovered organic materials. EPA is also proposing to consolidate all
compost designations under one item called ``compost made from
recovered organic materials.''


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