B E C A U S E :

There are sludge victims around the country . . .

people sickened from exposure to land applied sewage sludge biosolids . . .

and lawsuits pending on behalf of victims in Florida, Tennessee

and Pennsylvania . . . 

the following is a summary of why Rural America 

opposes the land application of sewage sludge . . . . .

RURAL AMERICA DEMANDS AN END TO THE LAND SPREADING OF MUNICIPAL SEWAGE
SLUDGE FOR THE FOLLOWING REASONS:

     BECAUSE the Federal Clean Water Act defines sewage sludge as a
"pollutant" [33 U.S.C.1362(6)];

     BECAUSE the Harper-Collins Dictionary of Environmental Science
describes 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 sewage
treatment plants";

     BECAUSE the US EPA acknowledges that the pollutants and pathogenic
organisms in sewage sludge ". . . upon exposure, ingestion, inhalation, or
assimilation into an organisms 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." [40 CFR
Part 503.9 (f)]

     BECAUSE official EPA policy is to dispose of landfill and Superfund
leachates, radioactive wastes, and toxic commercial and industrial chemicals
into public sewer systems, to be combined with residential sewage and other
pathogenic sources, with the resultant sewage sludge to be spread on the
land in Rural America;

     BECAUSE FEDERAL LAW permits every business and industry in the United
States to dump 33 pounds of hazardous wastes into public sewers every month
with no reporting requirements [ 40CFR 403.12)P)(2) ];

     BECAUSE the EPA's Toxics Release Inventory (TRI) and public records
indicate industrial pretreatment programs are inadequate, ineffective and/or
not being enforced in states around the nation to control the discharge of
toxic industrial chemicals into sewers.    And the TRI reveals that the
quantities of toxic metals and other hazardous chemicals being discharged
into public sewers are increasing; and EPA acknowledges that the wastewater
treatment process reconcentrates the pollutants in the treated sewage sludge
("biosolids");

     BECAUSE the waste industry in 1999 convinced Congress to exempt sewage
treatment plants  (POTWs) from any Superfund liability with regard to the
toxic pollutants processed by such facilities;

     BECAUSE the EPA acknowledges all treated sewage sludge ("biosolids"),
both Class A and Class B, contains toxic metals including arsenic, antimony,
beryllium, cadmium, chromium, lead, molybdenum and mercury; dangerous
pesticides; toxic, bioaccumulative poisons including dioxins, furans,
brominated flame retardants; and hazardous industrial wastes including
cyanide, polycyclic aromatic hydrocarbons and other volatile and
semi-volatile organic chemicals;

     BECAUSE the EPA allows Class B sewage sludge to contain significant
quantities of human pathogens [up to 2 million CFUs (colony forming units)
of fecal coliforms per gram of total solids, dry weight], and slaughter
house wastes, mortuary discharges and infectious hospital and institutional
wastes, including disease-causing bacteria, viruses, virulent antibiotic
resistant  microbes, protozoa, intestinal parasites and parasitic worms;

     BECAUSE the EPA has never conducted a risk assessment on the harm to
human health from the pathogens in surface applied (top dressed) sludge
including airborne pathogenic dusts,  viruses, bacteria, endotoxins, molds,
fungi, etc. despite increasing evidence from around the country that
neighbors of sludge sites are getting sick;

     BECAUSE the EPA acknowledges land applied sewage sludge emits
toxic/irritant gases including dimethyl sulfide, dimethyl disulfide, methyl
mercaptan, trimethylamine and ammonia, which CDC, NIOSH, OSHA, DOT, ATSDR
and other government agencies warn can cause great harm to human health if
inhaled or ingested ("ingestion" includes 'inhalation of bioaerosols, which
are deposited in the throat and upper airway and swallowed');

     BECAUSE a 1999 Risk Assessment conducted by Charles Gerba, Ian Pepper,
Scot Dowd and Suresh Pillai indicates people within 1000 - 1600 feet of
sludge/biosolids sites or sludge/biosolids stockpiles are at significant
risk (far in excess of EPA "acceptable" risk of l - 10,000) from airborne
sludge viruses and bacteria;

     BECAUSE a report published in November 2000 Journal of Agromedicine -
Dr. Susan Schiffman, Duke University, and Dr. John Walker, US EPA, lead
authors -- details the harm to human health from sludge odors, odorants,
bioaerosols and airborne particulates including " . . . eye, nose, and
throat irritation, headache, nausea, diarrhea, hoarseness, sore throat,
cough, chest tightness, nasal congestion, palpitations, shortness of breath,
stress, drowsiness, and alterations in mood" and " . . . exposure to
increased levels of particulates is associated with increased mortality
risk, especially among the elderly and individuals with preexisting
cardiopulmonary diseases, such as chronic obstructive pulmonary disease
(COPD), pneumonia, and chronic heart disease."

     BECAUSE THE AFORESAID SLUDGE/BIOSOLIDS DUSTS, GASES AND AIRBORNE
PATHOGENS CAN COMBINE to form a noxious miasma which can engulf and
adversely affects the health of neighbors of sludge sites;

      BECAUSE courts in California, Oregon and Kentucky have ruled that the
odors and emissions from sludge processing facilities are a "nuisance", and
the judges in Kentucky and California cases awarded monetary damages to the
sludge victims;

in June 2003 a jury in Augusta, Georgia found that sewage sludge killed
cattle and poisoned pastures and awarded the dairy farmer $550,000; and
farmers in New Hampshire, Florida, Tennessee and Pennsylvania have been sued
by people sickened by exposure to sewage sludge biosolids which was spread
on their land;

     BECAUSE the landspreading of  treated sewage sludge/("biosolids") has
caused sickness (and even death) in people around the country - (known as
"sludge syndrome") including nausea, vomiting, diarrhea, eye, nose and
throat burning and irritation, skin rashes and lesions, cysts, bloody noses,
eye infections, pneumonia, asthma and other respiratory illnesses, tumors,
immune system damage, viral and bacterial infections and a host of other
physical maladies;

(See -  http://www.sludgevictims.net

and http://www.cfe.cornell.edu/wmi/Sludge/INCIDENTS.htm   )

     BECAUSE in their July 2002 report, the National Research Council
acknowledged that despite the fact that sewage sludge is a complex mix of
pathogens and toxic chemicals which may affect human health:  "Because of
the data gaps and lack of risk assessment methods for complex mixtures, it
is NOT POSSIBLE to integrate pathogen risk assessment with chemical risk
assessment."  (Page 6)
http://books.nap.edu/books/0309084865/html/6.html#page_middle

     BECAUSE the landspreading of sewage sludge has caused sickness and
death of fish, livestock and family pets;

     BECAUSE sludge nutrients, toxins and pathogens are known to have
contaminated drinking water wells, ground water and surface waters around
the country;

     BECAUSE treated sewage sludge/("biosolids") contains  brominated flame
retardants, nonylphenols, surfactants, phthalates and other persistent,
bioaccumulative, toxic and  endocrine/hormone disrupting chemicals which
cause great harm to wildlife and aquatic life;

      BECAUSE Central and Northern European countries including Germany and
Denmark are moving away from land application because of the uncertainties
about endocrine disrupting compounds in sewage biosolids; and Switzerland
has already banned land application based on the precautionary principle;

     BECAUSE the EPA has never conducted a risk assessment into the risks of
the harm to wildlife, soil biota and other ecological biosystems from "top
dressed" (unincorporated)  sewage sludge;

     BECAUSE a recently released study by AMSA (Association of Metropolitan
Sewerage Agencies) shows that DIOXIN levels in 2/3rds of sewage biosolids
exceed the concentrations at which two EPA Risk Assessments show can cause
great harm to certain species of wildlife;

     BECAUSE the EPA has established the least protective sludge regulations
of any developed country in the world -- (Canada and European countries use
the "precautionary principle" - or "no net degradation to soil quality" -- 
to set limits on toxic metals from sludge in agricultural soils many times
lower than US EPA );

     BECAUSE the EPA Inspector General in April 2000 stated:

"EPA does not have an effective program for ensuring compliance with the
land application requirements of Part 503"; and

"Accordingly, while EPA promotes land application, EPA cannot assure the
public that current land application practices are protective of human
health and the environment."

     In February 2002, the EPA Inspector General stated:  "The agency (EPA)
can neither investigate nor keep track of all of the complaints of adverse
health effects that are reported."



     And in September 2002, the EPA OIG said "EPA does not know whether
current regulations, when adhered to, are protective of public health" and
"When it issued the rule, EPA committed to conducting a comprehensive
research program to assess the risks associated with land application of
biosolids, yet it has not yet done so."



     BECAUSE IN June 2001, Scientists at a Cincinnati, Ohio, workshop
sponsored by US EPA and USDA concluded present testing methods are
inadequate and a great deal more research must be done with regard to
pathogens  before treated sewage sludge/"biosolids" can be pronounced" safe"
;



     BECAUSE state "environmental/regulatory" agencies across the nation are
PROMOTING land application of treated sewage sludge/"biosolids"), and doing
nothing to respond to sickness, water contamination and other concerns of
Rural Americans who are suffering health and environmental consequences,
lower property values and destruction of their quality of life by the
disposal of this noxious waste in their communities;

      BECAUSE despite the fact that federal sludge rules say sludge disposal
is a LOCAL option,  sludge bullies have filed lawsuits in Pennsylvania,
Virginia, California and Florida to force this toxic/pathogen waste from
urban and industrial  sources on unwilling rural communities which seek to
protect themselves by enacting local sludge control ordinances;

      BECAUSE THE US EPA has made a concerted effort to cover up and avoid
any and all documentation and/or investigation into the sickness (and
possibly death) of sludge victims - humans and animals;

     BECAUSE the US EPA has given over $19 million of our tax dollars to the
WEF (Water Environment Federation - the lobbying and public relations arm of
the waste industry) to promote sludge spreading and hire pro-sludge
"scientists" " to rubber stamp waste industry/EPA sludge policies, and to
fund their campaigns to debunk and discredit sludge victims and people
seeking more protective sludge rules;

     BECAUSE in August 1999, the EPA weakened federal sludge rules (40 CFR
Part 503) -- by changing the wording of the certifications by the sludge
producers/sludge spreaders required under 40 CFR Part 503.17, so that they
NO LONGER have to certify that the "requirements" of federal law with regard
to pathogen reduction, vector attraction reduction, management practices and
site restrictions "have been met";

          BECAUSE the EPA has harassed and retaliated against any scientist
within its agency who dares to speak out in opposition to its
sludge/biosolids  (or other waste mismanagement) policies; and in May 2003
forced the resignation of renowned EPA microbiologist David L. Lewis because
of publication in prestigious scientific and medical journals in June and
July 2002, of his peer reviewed studies on adverse health effects reported
by sludge victims;

BECAUSE despite the fact that EPA and the waste industry promote sewage
sludge as "fertilizer", in fact in March 2003 at their 101st Anniversary
Convention in Anaheim, California, the National Farmers Union called for an
end to the land spreading of Class B sewage sludge biosolids;  and

        BECAUSE the highly respected Waste Management Institute of Cornell
Univerity, Ithaca, New York, has studied the land application of sewage
sludge for many years and has published a report in the International
Journal of Environment and Pollution, which concludes the EPA 40 CFR Part
503 sludge rules do not protect human health, agricultural soil and the
environment.

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Prepared by Helane Shields, Sludge Researcher

PO Box 1133, Alton, NH 03809 Phone/fax: 603-875-3842

Email: hshields@worldpath.net