exposing Baltimore children to Class A sewage sludge

April 17, 2008

Dear Sarah – and others . . . .

Regarding the children in Baltimore who were exposed to sludge in their yards, first of all “ORGRO” is Class A sewage sludge. This means pathogens are supposed to be “below detectable levels”, although EPA and waste industry acknowledge pathogens frequently regrow after treatment.

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)]

Pathogen reduction at the sewage treatment plant does NOTHING to eliminate toxic chemicals in Class A or Class B sewage sludge.

Official EPA policy is to dispose of landfill and Superfund leachates, radioactive wastes, and toxic commercial and industrial chemicals into public sewer systems.

In 2004 the US EPA Office of Inspector General issued a critical report saying industrial pretreatment programs are at risk, they are low priority with EPA, toxic pollutants are still being transferred to sewage treatment plants, and “the impact to human health and the environment of some of these pollutants may still not be known;”

Under the Bush Administration’s pro-industry, pro-polluter policies, there has been little or no effort to reduce toxic dumping into public sewers. Challenging economic times and foreign competition with relaxed labor and environmental laws, dictate that federal agencies should avoid burdening business and industry with the expenses of properly treating or recycling hazardous wastes.

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) ] and this same law provides for only a one time reporting if acutely hazardous wastes, or more than 33 pounds of hazardous wastes, are dumped into the public sewers.

In 2006, the Cornell Waste Management Institute released a peer reviewed study which found that some sewage sludges have such high levels of toxic pollutants that they exceed the US EPA’s Superfund Soil Screening Limits.

The 2006 EPA Toxics Release Inventory indicates over 5 billion pounds of toxic metals and other hazardous chemicals were dumped in US sewage treatment plants where the wastewater treatment process preferentially reconcentrates the pollutants in the sewage sludge – both Class A and Class B. And the EPA Toxics Release Inventory covers only about 600 of the tens of thousands of hazardous chemicals circulating in industry and commerce today. Most chemicals are untested, unmonitored and unregulated.

In 1999, the waste industry convinced Congress to exempt sewage treatment plants (POTWs) from any Superfund liability with regard to the toxic pollutants processed by such facilities. [In the summer of 2007, Milwaukee’s POTW benefited from this “no liability” protection when Class A sludge biosolids “Milorganite”which was spread on Milwaukee playgrounds and ballfields contained high levels of toxic PCBs which exceeded EPA Superfund limits, and the taxpayers are now stuck with the cost of cleanup.]

In fact, 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, PCBs, brominated flame retardants; and other hazardous industrial wastes including solvents, cyanide, polycyclic aromatic hydrocarbons and other volatile and semi-volatile
organic (carbon-based) chemicals, not to mention the drugs and pharmaceuticals which are showing up in surface waters, drinking water and sludge from the sewage treatment plants.

Thus, those little kids in Baltimore (and every family that spreads Class A sewage sludge in their yards) are being exposed to dangerous chemical pollutants. Kids, with their hand-to-mouth behavior, are most at risk from eating dirt and sludge.

In fact, in the Baltimore sludge experiment, according to sludge promoter Rufus Chaney of USDA, the kids were EXPECTED to eat the dirt/sludge:

"The idea was to have the sludge bind to the lead in the soil and make it less likely to be absorbed if consumed. The study found that it worked, Chaney said. He said other studies - which included feeding treated soil to rats, pigs and humans, showed a 69 percent reduction in lead absorption. The Hopkins study was not designed to check the possible impact on the health of children who lived in the houses, he said. "
http://www.baltimoresun.com:80/news/local/bal-md.sludge15apr15,0,3970131.story

Rufus Chaney’s approval of Baltimore kids eating sludge is in sharp contrast to a Canadian interview he did a few years ago, where he railed against topdressing sewage sludge on pastures, to prevent livestock from eating chemically contaminated sludge:


EXCERPTS FROM STATEMENTS MADE ON 2/7/2002 BY DR. RUFUS CHANEY: USDA PRO SLUDGE SPOKESMAN TO ERIK APEDAILE, SUSAN LIVER, IRWIN OSINGA SUBJECT: CANADIAN REVIEW OF HEALTH ASPECTS OF BIOSOLIDS LAND APPLICATION

"But when the fluid biosolids are spray applied on standing forages, the biosolids particles can get stuck to the forages . . . when such contaminated forages are grazed, livestock can get high exposure to xenobiotics in biosolids." (“xenobiotics “ = Studying the Metabolism and Disposition of Chemicals in Biological Systems -Xenobiotics include such substances as TNT, PCBs, chlorophenols and PAHs.)

If dewatered biosolids or composts are land applied, the biosolids fall to the soil surface rather than get spread out on leaves and stems of forages, and exposure is hardly different from the ingestion of surface soil model. If the biosolids are incorporated into soil, uptake to forages is low, but soil ingestion does allow some livestock exposure and absorption of xenobiotics. Grazing (not forage uptake) by animals could be getting these compounds into food and milk, especially if the biosolids are surface applied." Page A-2 IO: So a BMP (Best Management Practice) would be to not apply biosolids to pastureland?

Dr. Chaney: 'The BMP IS TO INCORPORATE THE BIOSOLIDS IF THE FIELD WILL BE USED FOR PASTURE. Biosolids can represent 12% of an animal's diet if fluid biosolids are surface applied . . . << 1% if incorporated (animals consume about 1.5% soil on yearly average basis; and if the biosolids are mixed with soil, the surface soil to which they have access contains greatly diluted biosolids."


Thank you for the opportunity to respond to the issue of EPA, USDA and HUD intentionally exposed minority children in Baltimore to toxic Class A sewage sludge.

Helane Shields, PO Box 1133, Alton, NH 03809 sludge researcher since 1996

http://www.sludgevictims.net - sludge victims up to May 2001
http://www.sludgevictims.com - sludge victims from May 2001 to present