OUR SEWAGE / SLUDGE - BIOSOLIDS POISONED FOOD SUPPLY
and the effects of bad science
"If only one bacteria survives treatment it can cause adverse health effects because, according to the Federal Drug Administration,
"A single bacterium can grow to millions in 10 to 12 hours! Water, wind, insects, plants, and animals can carry bacteria."
Jim Bynum 6/18/2008
Retired Safety Consultant
With at least 13 state food slander laws to contend with, and most states changing the laws to promote spreading
pathogenic disease organism polluted sewage / sludge - biosolids on food crops, grazing land and home gardens,it is
rather difficult to find a balanced perspective in the media or halls of science. No one seems to realize that in a
laboratory setting, these pathogens must be handled in Biohazard safety level 2 equipment. However, without a
good data base such as I have developed, it would still be very dangerous to write about sludge biosolids fraud,
as the AP editors have recently decided in Baltimore where pollutant contaminated sludge was put on yards in a black
neighborhood to protect poor children from polluted dirt. The reporters had good data, the editor just forgot that facts
are a little one sided after pressure was put on him. So, a new story was published by a different reporter with
balancing opinions from unnamed experts. Would the experts lie to a reporter? You be the judge.
Bacterial contaminated food products are taking a major toll on American health and the economy. Besides
contaminated beef, last year it was bacterial contaminated lettuce, spinach, and onions to name a few products. In the
latest round, the Associated Press reported McDonald's , Wal-Mart , Burger King, Kroger , Outback Steakhouse, Winn-
Dixie and Taco Bell have pulled bacterial contaminated tomatoes off the shelves and menu. In 32 states 552 people
have been tested and diagnosed with Salmonella poisoning. Not only is this extremely expensive for the companies
involved, as well as the farms and food brokers, the resulting lawsuits by victims could cost millions of dollars. It has
been reported that vegetables may take up disease organisms both inside and outside the plants. Scientists are
seeing long term health problems and fatalities from the delayed effects of bacterial food poisoning. The
interesting point is that municipalities are now using the long term health effects from bacterial poisoning they caused
by spreading pathogens in the environment to blame the health problem on smokers. Now they are going to protect
your health by banning smoking. It is also possible that some food contamination cases may actually be caused by
exposure to pollutant contaminated sewage / sludge - biosolids on lawns, parks and school yards which the AP
reporter didn't mention in the Baltimore story.
In reviewing the rules and science, the impression is given that if groups of disease causing organisms are mentioned,
such as heterotrophic bacteria, coliform bacteria and fecal coliform bacteria, it is perfectly acceptable to state
they don't cause disease, but instead indicate that disease causing organisms may be present. This is an example of
if you tell a big enough lie, it becomes gospel. Stating that Coliform does not cause disease may be scientific fact,
however, the big lie is that virtually every individual gram negative bacteria that make up the coliform does cause
serious diseases. A cheap simple pass or fail coliform test is used to make the lie work and it does indicate pathogenic
gram negative disease organisms such as E. coli and Salmonella are present. What about Virus contaminated food?
It is not politically correct to talk about government agencies authorizing the spreading deadly disease organisms in our
environment where they can poison our food supply. Nor is it politically correct to point out that scientific studies
supporting the use of disease causing organisms contaminated sewage / sludge - biosolids on our food supply simply
confirm that old adage, figures can lie and liars can figure out how to make the lie work. We first saw the
effects of this unholy combination of fake rules and scientific fraud after E. coli 0157 was created and took hold in
the cattle industry after 1982. After that we saw the effects in the vegetable markets and health care. Now it appears
we are seeing the same thing happen in the hog industry with Staphylococcus.
Besides E. coli and Salmonella contaminated beef, pigs have become infected with Staphylococcus and the news
stories imply that this superbug doesn't cause food poisoning. Generally the bacteria is not culturable in food
poisoning incidents and scientists must rely on finding the toxin to prove causation. That is expensive so scientists and
the media had rather not worry you as in the following example in the Wall Street Journal: "Ontario Veterinary
College researcher Scott Weese also detected these [Staphylococcus (MRSA)] bacteria in 10% of 212 samples of
ground pork and pork chops collected in four Canadian provinces. These particular strains of antibiotic-resistant bugs
haven't so far been shown to sicken patients, at least in North America. "
The reporter fail to check his facts. "Methicillin-resistant Staphylococcus aureus infections, which are potentially
deadly, are now responsible for an estimated 12 million outpatient visits each year for skin infections, said Jeff
Hageman, of the U.S. Centers for Disease Control and Prevention. "MRSA is epidemic in some regions of the country,"
In 2005 reports show there was 368,300 hospital stays, more than 94,000 life-threatening illnesses and almost 19,000
deaths.
Could the poisoning of our food supply have been prevented? If we go back to the CNN program Hazardous Harvest,
June 27, 1997, the answer would have to be yes. One EPA employee had the courage to state the facts. "Official U.S.
government policy in the Clinton administration is to grow food chain crops --the food supply of America -- on poison.
and not to tell the public," EPA engineer says." http://thewatchers.us/CNN-report-3.html
In 1996 there were about 80 million case of food poisoning (Ralph J. Touche - Chief Sanitarian - Public Health
Service). Ten years earlier, Charles P. Gerba of the University of Arizona published a study noting there were only
two million cases of food poisoning in 1986. In 1987 CDC estimated 9,100 deaths could be attributed to food poisoning.
Today, the major focus is on a few hundred cases of attributed to E. Coli and Salmonella poisoning of food products.
While cooking will normally eliminate the danger of E. coli and Salmonella poisoning, the toxins created by
Staphylococcus bacteria survive the cooking process, even when the bacteria do not, to cause food poisoning.
Current the federal agencies implicate animals as the source of bacterial food product poisoning and there is good
reason. "The 1985 Ohio study also noted that the World Health Organization (WHO, 1981) reported a positive
association and a cycle of infections of Salmonella from humans to sludge, to animals, and back to humans where
cattle grazed on sludge treated pastures. (Municipal Sewage Sludge Application on Ohio Farms: Health Effects. Dorn,
R.C., et al, Environmental Research 38, 332- 335)."
However, in 1998, laboratory testing of soil from the Alice Minter farm (our family farm) in Kansas City, Missouri
revealed E. coli and Salmonella contamination at over 800,000 cfu of each bacteria per 100 grams of soil. A fecal
Coliform - Fecal Strep test was done to verify the pathogens were of human origin. The Alice Minter farm was down
grade from Kansas City's sludge / biosolids disposal farm and received the bacterial contaminated stormwater runoff.
EPA's John Dunn first agreed to do the test and then refused to do any tests to confirm the pollution. However, EPA's
David Lewis did contact the laboratory to confirm the test methods and results. Lewis mentioned on of the test results
in his 1999 published article, Sludge Magic at EPA
In a 2002 published study, Lewis was part of a team of researcher who surveyed 54 individuals that lived near 10 land-
application sites in Alabama, California, Florida, New Hampshire, Ohio, Ontario, Pennsylvania and Texas. They found
that, "Affected residents lived within approximately 1 km of land application sites and generally complained of irritation
(e.g., skin rashes and burning of the eyes, throat, and lungs) after exposure to winds blowing from treated fields. A
prevalence of Staphylococcus aureus infections of the skin and respiratory tract was found. Approximately 1 in 4 of 54
individuals were infected, including 2 mortalities (septicaemia, pneumonia). This result was consistent with the
prevalence of S. aureus infections accompanying diaper rashes in which the organism, which is commonly found in the
lower human colon, tends to invade irritated or inflamed tissue."
It is no surprise then that federal agencies which approved the policy of using bacterial contaminated sewage effluent
on 12,000 acres in the Salinas Valley of California and sewage sludge everywhere (reclaimed water and biosolids)
on food crops as irrigation water and fertilizer can not (read refuse to) find the source of the contamination. Nor is it
surprising that these agencies claim there are only a few hundred people effected by each outbreak. In fact, CDC
lowered the food poisoning cases to 76 million in 1999, and still gives out that number as accurate data today.
People question these agencies actions at their own peril. When I questioned Kansas City officials and EPA about the
damaged caused to the Alice Minter farm by sludge biosolids runoff, I was told to keep my mouth shut or I would get
hurt. These guys were not kidding. EPA and the courts have ignored the laws and victimized the victims. In Kaufman's
case, EPA did away with his job as well as the EPA Ombudsman's office in violation of the intent of Congress. His case
against EPA is only now getting into court
Lewis was attacked by EPA's John Walker who tried to destroy his reputation. He was forced to spend his last years
till retirement at the University of Georgia. Because of this damaging attack, we were not able to use Lewis's expertise
and forced to sell the Alice Minter farm to Kansas City to use as a part of its sludge farm at a fire sale price. Lewis did
get involved in the death of dairy cattle for Boyce and McElmurray Dairies in Georgia, which they won in principle, even
though they were not adequately compensated for their losses.
Walker has been the prime mover behind the EPA program to dump toxic sludge on farmland as a fertilizer where it
poisoned crops and animals. When Walker was at USDA in 1973, he was the first to warn EPA that Salmonella was not
killed when lime was mixed with sludge, the bacteria was only inactivated (VBNC) for about 30 days. In 1994, Walker
was EPA PR program manager tasked with the job of covering up the sludge "horror stories." He assigned that task
to the Water Environment Federation which wrote a number of fact sheets victimizing the victims.
What we know today is that when enough money is on the line scientific studies can be produced and published which
have little relationship to facts. Several studies concerning Lewis's work are of serious concern here:
The results of the first "study" is described in a letter to the President of the University of Georgia by attorney Ed
Hallman, "The University of Georgia became directly involved in covering up the contamination on the McElmurray and
Boyce lands. Faculty members, including Julia Gaskin and Professor William Miller, accepted a grant from Robert
Brobst and other senior officials at the United States Environmental Protection Agency ("EPA") to knowingly publish
what Judge Alaimo determined to be "fudged," "fabricated," and "invented" scientific data, which were used to falsely
assert that my clients' lands were not contaminated. These EPA and University of Georgia employees then provided
the fake data to the National Academy of Sciences, which used the data to support EPA's sludge regulations. Finally,
Mr. Brobst and his co-authors at the University of Georgia provided the fake data to the USDA in an attempt to prevent
the McElmurray family from being compensated for their lost crops."
Professor Charles P. Gerba, University of Arizona and associates, jump into the fray with studies to show Lewis had to
be wrong about airborne staphylococcus infecting neighbors of sludge disposal sites and there was no danger from
exposure to the pollutant disease organisms in sludge biosolids:
2003, Evidence for the Absence of Staphylococcus aureus in Land Applied Biosolids, 2005, Potential Regrowth and
Recolonization of Salmonellae and Indicators in Biosolids and Biosolid-Amended Soil , 2005, A national study on the
residential impact of biological aerosols from the land application of biosolids 2008, Exposure and risk assessment of
Salmonella in recycled residuals
Before we address the most recent studies, we should review Gerba's 1986 study, Development of a Qualitative
Pathogen Risk Assessment Methodology for Municipal Sludge Landfilling.
Gerba only acknowledged 7 bacteria in sludge out of 53 pathogenic bacterial families indexed at
http://thewatchers.us/1_index-bacteria.html
1) Salmonella (1,700 types) which cause (Typhoid, paratyphoid and Salmonellosis). Like typhoid, paratyphoid is a
form of enteric fever. According to CDC, "During the toxic stage there is a 1-10% chance of intestinal perforation or
hemorrhage." With Salmonellosis, "the Salmonella infection may spread from the intestines to the blood stream, and
then to other body sites and can cause death unless the person is treated promptly with antibiotics. The elderly,
infants, and those with impaired immune systems are more likely to have a severe illness."
2) Shigella - Shigellosis/ (bacillary dysentery) -- fatality may be as high as 10-15% with some strains
3) E. coli (Enteropathogenic type) -- When Gerba made this list in 1983, E. coli 0157 had not been create yet. As a
group E. coli causes inflammatory diarrhea , destruction of red blood cells and kidney failure (hemolytic-uremic
syndrome), urinary tract infections, bacteremia, meningitis, severe, lung infection , pneumonia, abscesses in the lining
of the lungs (empyema), necrotizing "flesh eating" infections in the urinary tract and the abdominal cavity.
4) Yersinia enterocolitica (Gastroenteritis) -- According to CDC, it "occurs most often in young children. Common
symptoms in children are fever, abdominal pain, and diarrhea, which is often bloody." "In older children and adults,
right-sided abdominal pain and fever may be the predominant symptoms, and may be confused with appendicitis. In a
small proportion of cases, complications such as skin rash, joint pains, or spread of bacteria to the bloodstream can
occur"
5) Campylobacter jejuni (Gastroenteritis) -- According to CDC, "Campylobacter jejuni is the most commonly reported
bacterial cause of foodborne infection in the United States. Adding to the human and economic costs are chronic
sequelae associated with C. jejuni infection—Guillian-Barré syndrome and reactive arthritis. FDA says, "Environmental
stresses, such as exposure to air, drying, low pH, heating, freezing, and prolonged storage, damage cells and hinder
recovery to a greater degree than for most bacteria. Older and stressed organisms gradually become coccoidal and
increasingly difficult to culture."
6) Vibro cholerae (Cholera) -- According to CDC, "Approximately one in 20 infected persons has severe disease
characterized by profuse watery diarrhea, vomiting, and leg cramps. In these persons, rapid loss of body fluids leads to
dehydration and shock. Without treatment, death can occur within hours."
7) Leptospira (Weil's disease) -- According to CDC, "Symptoms of leptospirosis include high fever, severe headache,
chills, muscle aches, and vomiting, and may include jaundice (yellow skin and eyes), red eyes, abdominal pain,
diarrhea, or a rash. If the disease is not treated, the patient could develop kidney damage, meningitis (inflammation of
the membrane around the brain and spinal cord), liver failure, and respiratory distress. In rare cases death occurs."
Gerba also acknowledged 7 fungi, 4 Protozoa, 7 types of worms, which cause: deep tissue infections, subacute
chronic meningitis, respiratory disease, candidiasis (yeast infection), otomycosis (infection of the outer ear canal),
ringworm, athlete's foot, infection of hair follicles, anemia, abdominal pain, liver abscess, colonic ulceration,
malabsorption, nausea, diarrhea.
Gerba only acknowledged 15 types of very dangerous viruses which cause: fever, eye infections, meningitis
(inflammation of the protective membranes covering the brain and spinal cord), herpangina (mouth filled with painful
blisters), rash, respiratory disease, myocarditis (inflammation of the heart muscle), congenital heart anomalies,
pleurodynia (fever and intense abdominal and chest pains with headache), encephalitis (acute inflammation of the
brain), acute hemorrhagic conjunctivitis ( painful, swollen, red eyes, with conjunctival hemorrhaging and excessive
tearing), infectious hepatitis (liver disease - can cause lifelong infection, cirrhosis (scarring) of the liver, liver cancer,
liver failure, and death), gastroenteritis (inflammation of the gastrointestinal tract), diarrhea, vomiting.
When Gerba and associates came out with a study declaring they couldn't find Staphylococcus aureus in sludge
(biosolids), the stated purpose was to discount the research by Lewis and associates who found that "approximately
25% of 48 individuals who lived near land application sites and who had complained of chemical irritation had evidence
of S. aureus infections." However, perhaps a more important reason was to draw attention away from epidemic of
staphylococcus infections in Pima County (Tucson), Arizona and the fact that the aerosol toxins created by dead and
dying Staphylococcus bacteria are very deadly potential biological warfare agents.
In 1996, researchers at the Walter Reed Army Institute of Research found that, like E. coli 0157:H7, the living
Staphylococcus bacteria was not as deadly as it's toxins. They said, "Staphylococcal enterotoxin B (SEB), a primary
cause of food poisoning, is also a superantigen that can cause toxic shock after traumatic or surgical staphylococcal
wound infections or viral influenza-associated staphylococcal superinfections or when aerosolized for use as a
potential biologic warfare threat agent."
We need to go back to 1993 to review the science being used in 2003. Gerba said, "Currently, methods to determine
the risk of disease from pathogens in land-disposed sludge are inadequate because the sensitivity of pathogen
detection is poor. The application of recombinant DNA technology (gene probes and polymerase chain reaction) to
environmental samples may provide increased sensitivity for detecting specific pathogens in land-disposed sludge and
greatly improved risk assessment models for our exposure to these sources of pathogens." Ten years later, Gerba is
using inadequate methods to determine that one specific strain of Staphylococcus is not in sludge. Rather strange
since FDA says, "Staphylococci exist in air, dust, sewage, water, milk, and food or on food equipment, environmental
surfaces, humans, and animals."
I wonder if Gerba understands as Sabina Heim discussed in 2002 ,that" high-molecular-weight proteins, such as the
putative proteins enolase and ATP-synthase -chain, or the homologue of the elongation factor Tu (EF-Tu) of
Staphylococcus aureus, are dramatically reduced in VBNC (viable, but nonculturable) cells." James D. Oliver,
Department of Biology, University of North Carolina at Charlotte, further explains in 2005, "It is now abundantly
evident that numerous bacteria, both gram-positive and negative, both pathogens and nonpathogens, are capable of
entering into the VBNC state. There is much yet to learn of the physiology, biochemistry, and genetics of cells as they
enter and resuscitate from this physiological state, but such studies are underway by investigators in numerous
countries around the world. While the importance of VBNC cells in the initiation of human infection is not yet fully clear,
it appears that cells in this state retain virulence, and should be considered by those investigators and government
regulators involved in the public health."
One more point, in a 2001 Stefano Dumontet et al., study "The Importance of Pathogenic Organisms in Sewage and
Sewage Sludge" reported in the J. Air & Waste Manage. Assoc., they noted that "Bacterial pathogens in sewage sludge
contribute significantly to health problems, locally and globally." Not only that but, they found that "Staphylococcus
(coagulase positive strains) [NF]" (includes S. aurerus) have been isolated from sewage sludge.
2003, Evidence for the Absence of Staphylococcus aureus in Land Applied Biosolids,
As a 20+ year researcher of sludge, Gerba failed to use primary data when he stated, "The U.S. Environmental
Protection Agency has established two categories of biosolids that can be land applied." Part 503 is the "sludge rule"
and does not mention biosolids. Gerba does acknowledge the "-- S. aureus were detected in raw sewage samples,"
Testing of sludge for pathogens is hit or miss at best according to this study. The study acknowledges that even when
sludge was seeded with a known quantity of bacteria, there was only a "recovery efficiency of 8.7%." The authors
claim, "The MPN method of detection was utilized in this study rather than polymerase chain reaction (PCR) in order to
enumerate only viable S. aureus." What that means is that Gerba did not want to find the viable, but nonculturable
bacteria. The aerosol detection limits makes the study even more questionable with minimum detection limits from 18 to
155. If these scientists were intent on using standard testing methodology, then the minimum detection limit should be
the same for all samples.
Gerba leaves us with the limitation, "Investigators should consider careful and rigorous confirmation steps for the
identification of any bacterial pathogens in environmental samples as no medium is absolutely selective and
differential." In effect, this study failed because these scientists didn't address which one of the 50 strains of S.
aureus that have been studied they were looking for such as F31 (normal MBC, MLSB-sensitive) and F457 (raised
MBC, constitutively MLSB-resistant) and they should have tested for the deadly Staphylococcal enterotoxins in which
one outbreak effected 13,420 Japanese victims in 2002. Juliane Bubeck Wardenburg also points out in a 2006
study that, "By generating mutations that block the diacylglycerol modification of lipoprotein precursors, we show here
that S. aureus variants lacking lipoproteins escape immune recognition and cause lethal infections with disseminated
abscess formation, failing to elicit an adequate host response."
The scientists also failed to explain why they could only recover 8.7% of the seeded bacteria, while at the same time,
they could not find any of the pathogens passing through the treatment plant. An excerpt from the 1998 book Deadly
Deceit explains:
"It has been recognized in Germany, at least since D. Strauch published his paper "Survival of pathogenic
micro-organisms and parasite in extreta, manure and sewage sludge" in 1991, that" most pathogenic
agents can survive the treatment process" and the sewage treatment process causes some of the pathogenic disease
organisms to be absorbed or enclosed in faecal particles during the treatment process." "The problem of pathogen
detection in sludge, according to Lewis, "is that the sewage treatment process changes the outside crust of the
aggregates in sludge and only the pathogens on the outside of the aggregates are measured by standard tests." He
says that most of the microbes are trapped inside the aggregates. When ultrasound was used to break open the
aggregates of sludge the trapped microbes were revealed."
A WEF study in 2006 found that certain centrifugation processes would also release the bacteria from the
aggregates. They say, "Immediately after centrifugation, fecal coliform counts increased from very low or
nondetectable levels, often by as much as several orders of magnitude, at the four facilities where increases were
observed. This study only looked at seven facilities and only facilities using anaerobic digestion and high-solids
centrifugation for dewatering"
Not only that but, "According to Lewis, standard test methods underestimate the number of water repellent
contaminates. In looking at the aids virus found on medical and dental tools, Lewis discovered that the HIV virus, when
it was covered with a water repellent lubricant such as silicone, was still infectious after several days. The water
repellent lubricants such as silicon and petroleum products cover the pathogens and prevent them from being found
by standard test methods. It was only when he dissolved the lubricants with acetone or other solvents, that the
pathogens showed up in tests. "Body fluids also break down the lubricants surrounding the contaminates," he said"
This might explain why the Orange Water and Sewer Authority of CARRBORO, UNC-Chapel Hill, NC. uses flow
through bearing oilers on its digester air compressors which puts about 5 gallons of 90 weight oil in the sludge each
week per compressor. That can hide an awful lot of pathogens toward the Class A sludge product called biosolids.
Gerba understands that pathogens can be hidden by sludge particles. "Virus survival in the environment can be
increased through adsorption to organic or soil particles where they are protected from environmental influences
(Gerba et al. 1975;"
Another problem with the study is explained by Gerba in this excerpt from Deadly Deceit:
Straub, Pepper and Gerba say that the list of pathogens are not constant but keep changing:
"As advances in analytical techniques and changes in
society have occurred, new pathogens are recognized and
the significance of well-known ones change.
Microorganisms are subject to mutation and evolution,
allowing for adaptation to changes in the environment.
In addition, many pathogens are viable but nonculturable
by current techniques (Rozak and Colwell 1987), and
actual concentrations in sludge are probably
underestimated.(p. 58)
They add further:
Thus, no assessment of the risks associated with the
land application of sewage sludge can ever be considered
complete when dealing with microorganisms. As new agents
are discovered and a greater understanding of their
ecology is developed, we must be willing to reevaluate
previous assumptions. (p. 58)"
In 2004, the Pakistan Agriculture Research Department, (60), commissioned the sludge study, Impact of sewage
wastes (effluent sludge) on soil properties and quality of vegetables. Bacteria isolated from the- sludge were
E.coli. Staph aureus, Streptococcus spp., Bacillus subtilus & Pseudomonas spp. Bacteria isolated from the soil were
E. coli, Salmonella spp., Pseudomonas spp., Staphylococcus spp. & Bacillus spp. Bacteria isolated from the
vegetables were E.coli, Staph.aureus., Staph citreus & Bacillus megatarium.
In reviewing the following Gerba study on regrowth and recolonization we need to keep Oliver's study on bacterial
VBNC in mind. He said, "Cells enter the VBNC state as a response to some form of natural stress, such as starvation,
incubation outside the temperature range of growth, elevated osmotic concentrations (e.g. seawater), oxygen
concentration, or exposure to white light (Oliver, 2000c). These typically are environmental stresses that might be
lethal if the cells did not enter this dormancy state. In addition, a number of studies have found that processes which
are normally assumed to be bactericidal for bacteria may instead result in cells which reside in the VBNC state. These
include such treatments as pasteurization of milk (e.g. Gunasekera et al., 2002) and chlorination of wastewater (Oliver
et al., 2005).
2005, Potential Regrowth and Recolonization of Salmonellae and Indicators in Biosolids and Biosolid-
Amended Soil ,
You would think a group of scientists could at least get the name of the regulation right. Instead they lie and say, "The
United States Environmental Protection Agency (EPA) regulates the use of biosolids, and before being land applied,
treatment of biosolids must occur in order to achieve standards set by the 40 CFR Part 503 Biosolids Rule. Established
by the EPA in 1993," There is no biosolids rule, it is 40 CFR "PART 503--STANDARDS FOR THE USE OR DISPOSAL
OF SEWAGE SLUDGE"
If they can't get the name of the rule right, how could we expect these scientists to get the facts right? They say, "the
Part 503 rule set criteria for levels of metals, pathogens, and also vector attractants, which are safe to humans and
other animals when biosolids are used beneficially for land application."
It doesn't take a rockets scientist to figure out that EPA did not set safe criteria for all metals that could cause your
death. In fact EPA only included the somewhat less dangerous metals (even though they are above the hazardous
waste levels) for which pollution removal credits are allowed under Part 403, Appendix G. "Under Section 307(b)
(1), these credits are available (1) if the combined level of treatment by the indirect discharger and the POTW is
equivalent to the effluent limitations imposed on the comparable direct discharger and (2) if the granting of a credit
does not "prevent sludge use or disposal" in accordance with Section 405 of the Act (33 U.S.C. 1345)". Removal
credits are not allowed for six of the nine metals if the sludge/biosolids is disposed of in an EPA honest to God
permitted part 503 surface disposal site. Removal credits are not allowed for Beryllium, manganese, Silver,
Thallium, Thorium, etc, but they still are released in sludge biosolids.
The most dangerous metal is hexavalent chromium which is not only released from treatment plants in sludge
(30,000 ppm) but also it is created when the pH of sludge is raised to 11-12 by additional lime treatment. Not only that
but, EPA removed all information on the five metals that cause cancer by inhalation. EPA only set a level for one
pathogen (Salmonella) out of the coliform group of pathogens. Since only a few Salmonella may be thermotolerant,
the treatment plant was given a choice of use them or few thermotolerant pathogens lumped together in the fecal
coliform group it set as the criteria for establishing the safety of sludge biosolids. The fecal coliform group of
pathogens grow best in the laboratory at about 15 degrees higher than the coliform group. These pathogens are
inactivated (not killed) by a low level of treatment. EPA did not set levels for sporeforming bacteria or other pathogenic
bacteria that require a high level of treatment.
The fact is that EPA has never officially claimed that sludge use is safe:
1) EPA BOLDLY ADMITS TO THE LACK OF DATA ON CHEMICALS HARMFUL TO HUMAN HEALTH
2) "EPA concluded that adequate protection of public health and the environment did not require the adoption of
standards designed to protect human health or the environment under exposure conditions that are unlikely and
where effects were not significant or widespread." (Federal Register. vol. 58, p. 9252) A farm or home lawn
meets the last part of that definition.
3) "The term "toxic pollutant" [CWA term] is not used in the final part 503 regulation because this generally is
limited to the list of priority toxic pollutants developed by EPA. The Agency concluded that Congress intended
that EPA develop the part 503 pollutant limits for a broader range of substances that might interfere with the use
and disposal of sewage sludge, not just the 126 priority pollutants." (FR. 58, 32, p. 9327)
4) 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 (humans) or offspring (children) of the organisms."
5) EPA did not do a risk assessment for known cancer causing inorganic metals, organic chemicals or
pathogens. A true case of figures can lie and liars can figure.
The study authors states, "Due to limited available data regarding regrowth of salmonellae in biosolids used for land
application, there are conflicting views on this topic. Some studies have shown that regrowth does occur, while other
studies have shown that regrowth does not occur. These differences are most likely due to whether indigenous
salmonellae are studied or whether biosolids are reseeded with salmonellae."
EPA and WEF have assured us these conflicts were resolved 30 or 40 years before part 503 was forced upon the
public. It comes down to whether the study is done by a true scientist as Gerba appeared to be in 1986 or a sludge
industry hack beguiled by grant money. This appears to be another effort to overcome John Walker's comments
recorded in "Proceedings of the Joint Conference on Recycling Municipal Sludges and Effluent on Land",
July 9-13-1973, pp. 39-47. Sponsored by EPA, USDA, and National Association of State Universities and Land Grant
Colleges, where it was acknowledged that limed sludge made Salmonella disappear for about 30 days at which point
they returned to the original count. EPA has always acknowledged this as the potential for explosive regrowth. EPA
puts it this way, "Typically, after the Class A pathogen requirement is met, the sewage sludge is left without an
adequate density of predator or competitive organisms to compete with pathogenic bacteria such as Salmonella sp.
bacteria. As a result, regrowth of pathogenic bacteria in the sewage sludge will occur if a small number of those
bacteria survive treatment or when bacteria are introduced into the sewage sludge inadvertently. When vector
attraction reduction precedes treatment for pathogens, regrowth of the pathogenic bacteria can occur." (FR. Vol 58,
No. 32, p.9348)
What is most interesting about this study is the reference to heterotrophic (HPC) bacteria. As Sabina Heim points out,
"It has been demonstrated elsewhere that the major part of the bacterial population present in the environment cannot
be detected by traditional culture techniques (e.g., determination of CFU). Although they cannot be cultured, viable
bacteria can be visualized when a direct viable count method is used."
The implication of the study is that high levels of HPC bacteria are not pathogenic. However, heterotrophic bacteria,
include all pathogens and according to the study, "After 8 weeks of following potential regrowth events, HPC bacteria
were assayed to evaluate biotic competition. After rainfall, HPCs reached levels of 2 x 1010 CFU per dry g and
decreased during the next few weeks until stabilizing around 109 CFU per dry g for the remainder of the experiment."
The study implies that Salmonella is not a part of the fecal coliform group of bacteria. It also implies that the coliform
group of bacteria are not pathogens. Coliform is a generic name for the gram negative group of pathogenic bacteria
which ferment lactose at 37 °C. Fecal coliform is a generic name for the mutant strains of thermotolerant gram
negative pathogenic bacteria that ferment lactose at 44.5 °C. Salmonella is one of the coliform group mostly
inactivated by heat stress at the higher fecal coliform test temperature that tends to mostly identify E. coli. That would
explain why Salmonella counts were low when Tucson's extremely dry temperature exceeded 40 C, and why E. coli
counts were not reduced.
Gerba describes the stessors which create the VBNC phenomenon, yet claims the bacteria are dead. He said, "The
importance of the rate of desiccation on survival of organisms was seen with fecal coliforms in the field experiments.
Death of the fecal coliforms was fairly rapid during the first 6 weeks, when temperatures were high and humidity was
low, causing the beds to dry fairly quickly. Class A levels were achieved quickly during this time. The rate of die off was
much slower during the second drying cycle when lower temperatures and higher humidity were present, resulting in a
lower rate of desiccation."
Gerba's experiment didn't do the job. He said, "Fecal coliforms survived longer than salmonellae during the first 6
weeks of the study when air temperatures in Tucson exceeded 40°C. Salmonella concentrations were below Class A
levels when the percent solids of the biosolids was only 17%, whereas fecal coliforms did not decrease to Class A
levels until the biosolids were fairly dry (92% solids). Ultimately, Class A regulation levels for fecal coliforms (<1,000
MPN per g) were achieved during weeks 5, 6, and 16 through 22, while Class A regulation levels for salmonellae (<3
MPN per 4 dry g) were achieved during weeks 3 through 6, 14, and 18 through 23. Increased numbers of both
organisms were seen during week 7, when the biosolids still had an average percent solids of 91%. Rainfall increased
after week 7, and the percent solids of the samples decreased to 3.5%. At this time, a large amount of standing water
was present in the concrete-lined bed, which caused the biosolids to become completely saturated. During the next
several weeks when moisture levels were high, fecal coliforms and salmonellae grew to levels exceeding the initial
concentrations seen at the onset of the study and in excess of Class A standards. Due to the unexpected large
increase in Salmonella numbers during week 7 through 12, all dilutions assayed were positive, so the Salmonella
numbers presented in Fig. 2b may represent values lower than actual Salmonella numbers that were present.
Concentrations for both pathogens and indicators remained elevated for the next several weeks and only began to
decrease as the concrete beds slowly started drying. Class A levels were again achieved for salmonellae on week 18,
at which time none were detected. Fecal coliform numbers were within Class A levels on week 16 but were still detected
throughout the remainder of the study. Unlike salmonellae, a second increase in numbers of fecal coliforms was seen
during week 23 after another rainfall event."
After 35 years of claiming "sound science", Gerba finally admits the industry didn't know what it was doing. He said,
"In the field studies with Ina Road biosolids, Salmonella levels were extremely high at times when fecal coliform levels
were below Class A biosolid target levels. There is a choice of either examining samples for fecal coliforms or
salmonellae when determining Class A status of a sample. If salmonellae had not been measured, the biosolids may
have been assumed to reach Class A levels based on fecal coliform levels, when in reality the Salmonella levels were
high and the biosolids were clearly not of Class A status. This represents an example where monitoring for indicators
would have resulted in a false-negative result with respect to the presence of salmonellae. However, it is important to
recognize that drying beds are not a Class A-approved process. It also demonstrated that the use of concrete drying
beds will allow for the collection and retention of moisture from rainfall events, allowing either regrowth or reinoculation
of salmonellae and fecal coliforms from other sources. In the biosolid laboratory studies, it was shown that fecal
coliforms after wetting regrew to levels that exceeded Class A standards, whereas regrowth of salmonellae was not
detected. Hence, as in the field studies, the presence of indicator organisms did not always correlate with Salmonella
levels. The fact that indicators were able to regrow is probably due to the increased number of surviving coliforms
(higher than the threshold necessary for regrowth). "
Climate has much to do with survival as Gerba reported in his 1986 study. "Hess and Breer (1975) reported that
samonellae on grass treated with sludge could survive for a little less than 16 months in the climate of Switzerland, but
most reported times are shorter."
There was more behind the following study on bioaerosols than one might think. In 2005, Gerba appeared to be trying
to protect his reputation among the folks in Pima County, where Tucson and the University of Arizona are located. Pima
County has allowed the use of sludge as a fertilizer since 1983. By 2005, Methicillin Resistant Staphylococcus aureus
(MRSA) had become epidemic in Pima County. Reporter Carla McClain found: "A single emergency room, at Tucson
Medical Center, has treated 541 [MRSA] cases this year — triple the number TMC saw in 2003." Furthermore, the
University Medical Center, has had 483 MRSA cases in its emergency or urgent care center in the past year." One
should know that these are only two of the ten hospitals in Pima County.
She said, "the State of Arizona only started tracking severe, invasive [necrotizing fasciitis in Tucson] cases of
MRSA last year and now average 125 a month statewide." She said, "To date, 1,305 invasive cases have been
reported, with 132 in Pima County. Deaths have not been tracked."
Before Staphylococcus turned deadly in Pima County, fecal streptococcus mutated and began hitting the Indians at an
infection rate of 10 Indians to 1 other resident. In a CDC study, the conclusion was, "Significant changes occurred in
the spectrum of invasive group A streptococcal infections in Pima County, Arizona, between 1985 and 1990. Native
Americans were at increased risk of acquiring these infections." "Karen Brandel, reported in Tucson Weekly,
DECEMBER 22, 1997, "In 1990, Tucson saw an outbreak of invasive Strep A, according to Ken Komatsu, of the
Arizona Department of Health Services. The number of cases increased so dramatically that the state mandated
emergency measures, requiring physicians to report every case for an 18-month period. In October 1993, the state
again added Invasive Strep A to the list of diseases that must be reported to the Health Department."
Could the sludge and bacteria be aerosolizing off the sludge sites and infecting Pima County residents? According to
Gerba in 1986, they could. "He noted organisms in bioaerosols could be transmitted by inhalation or by contact after
the settled on a surfaces which humans come in contact with. He also noted suspension of the sludge particles would
be possible under windy conditions. Gerba also noted "dried sludges" may be very light and fine in texture and,
therefore easily resuspended" Exposure may be direct or aerosols may contaminate equipment. Animals and could
also transport contaminated sludge offsite."
"In Canada, the government recognizes that exposure to dried sludge will cause the respiratory disease "extrinsic
allergic alveolitis". It is called: Sewage sludge disease." A Yellow Alert fact sheet from Pima County Department of
Environmental Quality, (185) 2004, states, "Scientific studies have linked breathing particulate matter to a series of
significant health problems, including: aggravated asthma; increases in respiratory symptoms like coughing and difficult
or painful breathing; throat irritation, chronic bronchitis; decreased lung function; and premature death." The fact sheet
states, "Particulates come from a variety of sources such as, .... tilled fields. In addition, wind-borne particulates can
travel into the valley from other areas or be generated locally."
As we noted in Airborne aerosols: pathogens, Toxins, chemicals and metals (pollutants) in SLUDGE/BIOSOLIDS
"Scientists at the Jet Propulsion Laboratory have found that dust particles can carry multiple spore forming bacteria on
a single speck of dust which may survive all treatment processes. In a study of dust particles entering space craft at
the Jet Propulsion Laboratory, California Institute of Technology, Y. Lin, et al., Quantification of spore-forming bacteria
carried by dust particles, state, "Our data also confirms the existence of multiple spores on a single particle and spore
clumps." In another study, Myron, T, et al., Bacillus odysseyi sp. nov., a round-spore-forming bacillus isolated from the
Mars Odyssey spacecraft, found, "Of all strains tested, the spores of this strain were the most consistently resistant
and survived all of the challenges posed, i.e. exposure to conditions of desiccation (100 % survival), H2O2 [hydrogen
peroxide] (26 % survival), UV radiation (10 % survival at 660 J m-2) and gamma radiation (0·4 % survival)."
Knowing that the real aerosol danger is from dried sludge and that bacteria and viruses are absorbed in moist sludge
particles, Gerba focused on aerosols from sludge disposed of with at least 85% liquid content.
2005, A national study on the residential impact of biological aerosols from the land application of biosolids
Gerba said, "This present study was conducted to evaluate the microbial concentrations within biological aerosols at
several class B biosolids land application sites throughout the USA." A serious limitation was "Samples were collected
for a total of 20 min or c. 250 l of sampled air."
The authors state, "Downwind aerosol samples from biosolids loading, unloading, land application and background
operations were collected from all sites. All samples were analysed for the presence of HPC bacteria, total coliform
bacteria, Escherichia coli, Clostridium perfringens, coliphage, enteroviruses, hepatitis A virus and
norovirus. Total coliforms, E. coli, C. perfringens and coliphage were not detected with great frequency from any
sites,"
It seems Gerba found a new bacteria since his 1986 risk assessment, Clostridium perfringens. To find the bacteria, he
said, "All samples were heat shocked at 70°C for 20 min prior to sample analysis." Then incubated for "1–2 d at
44.5°C." Why would he do this. EPA's partners claims composting sludge at 55 °C kills all bacteria. Not only that but,
according to EPA, in "Pasteurization—The temperature of the sewage sludge is maintained at 70 degrees Celsius or
higher for 30 minutes or longer."
In the Johns Hopkins Bloomberg School of Public Health (2000) study using sludge to cover up lead problems in a poor
black Baltimore neighborhood, the researchers state, "Among biosolids, only Class A (pasteurized to prevent pathogen
risk to residents (MDE COMAR 15.18.04)) products (e.g., OrgroR composts) may be used to amend residential soils at
the rates needed to attain reduced Pb bioaccessibility and bioavailability;" Why would John Hopkins researchers lie
about the sludge being pasteurized when as Gerba's study shows it doesn't kill all bacteria. Of course we have to
wonder why the Baltimore City Compost Facility operators would lie and say they provide "complete sterilization
required under Federal 40 C.F.R. Part 503.32 and 503.33 for a Class A end product." In the first instance
pasteurization doesn't kill all bacteria and depends on refrigeration to prevent regrowth. In the second instance,
sterilization destroys all bacteria, viruses, helminths, protozoa, fungus and yeast and it is not required by EPA.
Yet, Gerba seems to imply that Salmonella is not a part of the coliform group of bacteria when he said, "this study
assumes that Salmonella has a direct correlation to coliform bacteria present in biosolids to assume the
pathogen load in the air. Faecal coliform bacteria do have a relationship with Salmonella in biosolids,
which has been previously demonstrated (Yanko 1988). However this relationship may not be present
when considering other pathogenic bacteria and may not be relevant to aerosols."
Yanko actually found and noted the VBNC phenomenon after sludge compost treatment and said, "significant
increases in bacterial populations, including salmonellae, occurred during subsequent production of commercial soil
amendment products." EPA used this study to justify promoting sludge composting.
Clostridium perfringens is a spore bacteria. The toxin causes necrosis [necrotizing - death] of the surrounding tissue in
association with Staphylococcus and Streptococcus and may be spread on dust particles. Strange that Gerba would
not test for any of the sporeforming fungi such as coccidioidomycosis which is killing people in his home town
There is one hell of a limitation on this study. According to Gerba, "It is noteworthy to state that this study does
not take into account other pathogenic bacteria present in biosolids and assumes that the greatest risk
would be from a pathogenic bacterial genus (Salmonella) that is more prevalent in biosolids."
In the study Polyphosphate accumulation by bacteria isolated from activated sludge (1999), M Sidat et.al., reported,
"Lötter (1985) reported gram-negative organisms to be the dominant organisms in the activated sludge system.
Results illustrated in Fig. 2 indicate the predominance of gram-positives in the sludge, found to be 42% of thetotal poly-
P population. These results support work by Brodisch and Joyner (1983) who reported the predominance of gram-
positive organisms throughout their laboratory-scale activated sludge system. They reported the gram-positive
population to be 34.5% in the aerobic zone. The figure also indicates that Staphylococcus spp. were the predominant
gram-positives, forming 40% of the gram-positive population isolated from the sludge followed by Streptococcus spp."
In 1986 Gerba only discussed 15 viruses in sludge. By 2001, he reported, "There are more than 140 different types
of enteric viruses excreted by man that can find their way into domestic sewage and biosolids .... the enteroviruses are
the largest group of enteric viruses causing some of the more serious illnesses, particularly in children."
Finally, Gerba totally ignores the threat of infection from dried biological aerosols blowing off the site where neighbors
are exposed 27/7, 365 days a year. He said, "risk of infection posed to the biosolids handler (i.e. occupational
exposure) is far greater and can reach as high as 34% annually from exposure to coxsackievirus A21 and
2% annually from exposure to Salmonella spp. as reported by Tanner (2004). This is expected as
occupational exposure takes place on a daily basis (250 d year)1) where as residential exposure is more
incidental and passing, typically for only a few days per year."
Knowing that viruses are the most deadly pathogens in sludge, we have to wonder why Gerba would waste his time
(and someones money) implying that he could actually do a risk assessment on Salmonella in sludge when even EPA
will not open that can of worms.
2008, Exposure and risk assessment of Salmonella in recycled residuals
Charles P. Gerba, Nohelia Castro-del Campo, John P. Brooks and Ian L. Pepper
This study is important not only because it claims that regrowth of pathogens makes Class A sludge more dangerous
than Class B sludge, but because Ian Pepper appears to have forgot or maybe just disclaims the study findings in a
June 13, 2008 AP article on the Baltimore lead study in the black neighborhood.
Gerba should have read EPA's take on biosolids exposure before he put his name on this study.
Gerba said, "Results of the risk characterization imply that the risk of human infection from direct contact with Class B
land applied residuals and subsequent ingestion is low. In contrast, the risk from direct contact with Class A residuals
following regrowth is greater. Risks from airborne transport of Salmonella via bioaerosols away from a Class B land
application site are also low. However, once again the risk from aerosols resulting from biosolids in which regrowth had
occurred was greater."
What was surprising is that Gerba tested the heat dried Milwaukee sludge "Milorganite" and found, "Salmonella
concentrations following regrowth in saturated Class A biosolids were approximately 106 CFU/g as reported in two
earlier studies" As noted earlier, there should not be more than 3 bacteria in 4 grams of Class A sludge for public
contact.
David Lewis reported this problem in his 2003 study A High-Level Disinfection Standard for Land-Applied Sewage
Sludges (Biosolids) He said, "Also, as is the case with food products, sewage sludge that is heated or otherwise treated
to kill pathogens is still subject to pathogen regrowth. In fact, because most of the competing microorganisms are
eliminated, it is even more conducive to pathogen regrowth."
Even the dean of John Hopkins School of Public Health claims to use Milorganite. Strange he would be using
Milorganite from Milwaukee instead of Baltimore's own Orgro sludge fertilizer he used in a black neighborhood study on
lead in soil?
John Hopkins scientists where a part of a $446,000 dollar study in 2000 which spread an even less well treated Class A
Baltimore sludge on 9 yards in a black Baltimore neighborhood. They say two wrongs do not make a right and it was
true in this case. Spreading pollutant (pathogens and metals) contaminated sludge compost on yards to protect the
poor black kids from eating lead contaminated dirt had to be dumb, even for USDA's Rufus Chaney and EPA.
They know that biosolids compost is killing us. EPA states the limitations of use, "Potential environmental impacts
may result from both composting operations and use of the compost product -- Survival and presence of primary
pathogens in the product -- Composting is not a sterilization process and a properly composted product maintains an
active population of beneficial microorganisms that compete against the pathogenic members. Under some conditions ,
explosive regrowth of pathogenic microorganisms is possible -- Dispersion of secondary pathogens such as Aspergillus
fumigatus, particulate matter,other airborne allergens."
Kennedy Krieger Institute & Johns Hopkins Bloomberg School of Public Health issued a press release April 21,
2008 defending their actions which indicate they did not do basic research. Now we see, neither they or AP's editors
are requiring any real research.
Even scientists can be fooled as AP reporter Malcolm Ritter found, June 13, 2008, "For about 20 years, Dr. Michael
Klag has used a fertilizer made from Milwaukee municipal sludge on azaleas and yew shrubs at his suburban Baltimore
home. And Klag, dean of the Johns Hopkins School of Public Health, says he's never had any question about its
safety." Can you imagine a doctor involved in public health spreading Salmonella and E. coli in his yard where the
wind, pets and children could take them into the home?
That could be why, " he has found himself reassuring the public about a similar product, a compost made with treated
municipal sewage sludge in Baltimore. Johns Hopkins researchers spread it on nine yards in poor black Baltimore
neighborhoods in an experiment eight years ago."
Ritter said, "And while the [original] AP story [by AP writers Heilprin and Vineys] said families in the Baltimore
experiment weren't told of safety disputes and health complaints regarding use of treated sludge on land, Klag's school
says it doesn't know of any research suggesting the compost itself poses a known risk to people."
Ritter quotes "Mike Silverman, the AP's senior managing editor, said the story suggested the compost could be riskier
than has been shown so far." "It is a subject of scientific debate," Silverman said. "Many researchers believe the
compost is safe, but there are some who believe it may be dangerous and should be studied further." "The original AP
story leaned too heavily on the latter view. That was unbalanced, and it created a distorted impression about the level
of risk in the Baltimore experiment." Doesn't the media believe in dealing with facts anymore? The researchers lied, as
noted above, when they told the poor black families the sludge compost was pasteurized and the compost facility lied
when the operators said the sludge compost was sterilized as required by EPA.
Ritter said "Another [NRC] committee member, Ian Pepper of the University of Arizona, agreed that the report was
"almost entirely focusing on Class B. ... The potential hazards associated with Class A are minimal." (Pepper directs a
National Science Foundation center on water quality that receives some industry funding)." Pepper has a strange
sense of humor. That is like saying the potential hazards associated with roadside bombs in Iraq are minimal just
because there are not many people at that spot at that time.
And finally, "Experts contacted recently by the AP generally said they didn't consider such material to be dangerous."
Ritter should have read the Maryland sludge rules. The study indicates that the sludge compost did not meet Maryland
requirements under 26.04.06.09 J. Handling (1)
(c) Sewage sludge compost for unlimited distribution to the general public shall contain 10 percent or greater by weight
calcium carbonate equivalent.
(d) When distributed, a label shall accompany the treated sludge. The label shall identify the product as containing
sewage sludge, and give instructions for its proper use. The Department may require that specific restrictions,
warnings, or a caution statement be included on the label. For sewage sludge compost for general distribution to the
public which contains more than 4 percent iron on a dry weight basis, the label shall warn against using the compost on
pasture land.
(e) A quality control program approved by the Department shall be instituted to assure that all treated sludge to be
distributed meets the Department's standards regarding the destruction of primary pathogenic organisms and the
limitation of heavy metals and other contaminants.
(f) A recordkeeping and reporting system shall be maintained as prescribed by the Department. This system shall
contain, as a minimum, provisions for keeping distribution records, results of all tests performed as a part of the quality
control program, and procedures for regular reporting of this information to the Department.
The study indicates there was no written documentation as to the quality of the sludge compost, therefore no label.
What is even more damning is the researchers didn't try to find out what was in the sludge compost until 3 years after
the study and by then the information given was 4-5 years old. The authors state, "For the year preceding the study
(1999), the average metals concentrations (mg kg1 dry weight) for OrgroR biosolids in general were as follows:
As=18, Cd=7, Cu=212, Pb=109, Hg=1, Mo=9, Ni=13, Se=8, Zn=440 (personal communication , USFilter,
2003)." Not only that but they were citing other studies done after the fact.
Silverman and Ritter should have talked to the real national sludge expert before caving in to John Hopkins PR blitz --
Attorney Ed Hallman.
We have to wonder who the experts were Ritter talked too and you will too after reading a Letter to Congress
concerning the Fraudulent Baltimore Soil Lead Study in a Black Neighborhood:
The first thing we note about this risk assessment study is that Gerda looked for mutant high temperature
thermotolerant Salmonella in the fecal coliform range where Salmonella is stressed and fails to thrive in the culturable
state. He said, "After 24 h in a circulating water bath at 43 C, a loopful of the enrichment was streaked onto Hektoen
Enteric agar (Difco Co., Detroit, MI). Presumptive colonies were confirmed using Triple Sugar Iron agar and Lysine Iron
agar (Difco Co., Detroit, MI) slants."
In spite of quoting Yanko earlier who noted that Salmonella did regrow in compost treated sludge, Gerba said, "Since
regrowth in Class A biosolids has been shown to occur under saturated anaerobic conditions, great care must be
taken when Class A biosolids are stored prior to land application. Specifically such biosolids should be covered to
prevent saturated anaerobic conditions that could occur following rainfall events. Without such regrowth events,
risks of infection from biosolid-borne Salmonella are low. "
Gerba and EPA have failed to acknowledge the health damaged that can be caused by fungi that may be in
compost, on foods and spread on dust from sludge sites as this excerpt from Airborne aerosols: pathogens,
Toxins, chemicals and metals (pollutants) in SLUDGE/BIOSOLIDS shows for Pima County, Arizona.
."An important fungal disease coccidioidomycosis is spreading in the southwest and west through the air.
In an article "Valley fever severity rises to level that is 'unbelievable'" Reporter Carla McClain (166) 2006, ARIZONA
DAILY STAR , said its "Known scientifically as coccidioidomycosis, valley fever is caused by a soil fungus that grows
only in parts of the southwestern United States, Mexico and South America. When inhaled, the fungal spores usually
attack the lungs, but they can spread through the bloodstream to the brain, skin and bones to cause severe,
sometimes fatal disease." "It can take only one spore to cause an infection, even a serious infection," said Dr. John
Galgiani, director of the UA's Valley Fever Center for Excellence." "With monthly case numbers also spiking statewide,
Arizona expects to easily surpass last year's total 3,778 cases." "The problem is starting to show up in the records. In
Pima County, a total of 259 valley fever cases have been reported in the most recent three-month period, from
November through January. That is an increase of more than 40 percent over the 183 cases reported during the same
period last year."
"According to a recent (April 2006) report, there were 2,000 cases in Arizona in the first three months of the year. As
we understand the general theory, what we are dealing with is very ancient pathogenic spores in the soil created by a
fungi, which bioaersols with dust under windy conditions. However, the dramatic increase in infection rates appear to
parallel the increased spreading of sludge on dry desert soils which, according to some scientists, also contains the
spores that cause coccidioidomycosis (Valley fever
The NAACP has called for a Congressional Hearing on sludge. Now might be a good time to write your Senator and
Congressman supporting the Hearings which is being called by:
The Honorable Barbara A. Mikulski U.S. Senate
503 Hart Senate Office Building Washington, DC 20510-0001
The Honorable Benjamin L. Cardin U.S. Senate
509 Hart Senate Office Building Washington, DC 20510-0001
The Honorable Elijah E. Cummings U.S. House of Representatives
2235 Rayburn House Office Building Washington, DC 20515-2007
Senator Barbara Boxer is expected to Chair a hearing in July 2008
410 Dirkson Senate Office Building
Washington, DC 20510