HELP FOR SEWAGE VICTIMS, Inc
Jim Bynum, VP                                                                                                    3-13-2010
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Fifteen Reasons to Ban Sludge/
                   Neither the Laws or Regulations recognize the term biosolids

When the government wants to confuse the public as well as the legal system, it simply changes
the name of the problem it wants to cover up, especially when the problem is the disposal of
hazardous sewage sludge. Currently, there is no law or regulation that even implies sewage
sludge might be safe for use as a fertilizer. The government agencies and industry do try to hide
the fact that specific gram negative bacteria are pathogens by using the generic term coliform
for those that are culturable at 37°C and fecal coliform for the very few that are culturable at
44.5°C.  The following 15 points give a brief overview of the danger to public health, food supply
and water supply as treated sewage and sludge spread bacteria and other pathogens.  The test
states that if the bacteria is not culturable at (44.5°C--112.1°F) it is not a fecal bacteria.
Strange, since the
human body could not survive that type of internal temperature and most
fecal bacteria go dormant to survive.

1. EPA test Method 1681 for human type Escherichia coli (E. coli) uses high heat (44.5°C--
112.1°F) to suppress the growth  of  
E. coli and stop the growth of 29 other specific gram
negative bacterial pathogens in sludge
,  leaving less than 3%  of pathogenic E. coli culturable
by standard laboratory methods.  According to EPA, “Since coliforms from other sources often
cannot produce gas under these conditions, this criterion is used to define the fecal component
of the coliform group.” “Fecal coliform bacteria, including Escherichia coli (E. coli), are commonly
found in the feces of humans and other warm-blooded animals, and indicate the potential
presence of
other bacterial and viral pathogens.“
http://www.epa.gov/waterscience/methods/method/biological/1681_1.pdf

2. An internet search reveals optimum growth for E. coli and other coliform  is at 35-37°C (95-
98.65°F).  E. coli and other coliform are responsible for over
50% of hospital acquired
infections. Infections include but are not limited too:
bacteriamia and septicemia; brain
abscesses; diarrhea; endocarditis; gastroenteritis; necrotizing meningo-encephalitis; necrotizing
fasciitis; mastitis -- inflammation of the breast; meningitis; pneumonia; Honeymoon cystitis --
Urinary Tract Infections, rheumatoid arthritis, septic arthritis; thrombosis of femoral artery;
Neonatal
death and adult deaths, mostly women.  Five percent of the drinking water tests are
allowed to fail the coliform test for the gram negative bacteria causing these diseases.

3. EPA’s Method 1681 lays out a complex mathematical formula for enumerating E. coli based
on Multiple-Tube Fermentation dilutions for 7 sludge samples collected over a 2 week period to
determine the most probable number of E. coli bacterial colonies found in the test, without any
regard for the actual number of bacteria in each colony. The colonies are reported as most
probable number of colony forming units (CFU), that is, at the beginning of the test.

4. While EPA and the sludge industry claim  there is no risk to the public from exposure to
sludge, it warns in Method 1681, “Field and laboratory staff collecting and analyzing
environmental samples are under some risk of exposure to pathogenic microorganisms. Staff
should apply safety procedures used for pathogens to handle all samples.”

5. While EPA acknowledged in 1995
it has not done a risk assessment for pollutants, Part
503.9(t) warns a “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.”

6.  The above documentation makes sludge a very dangerous hazardous waste according to  
the
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) (Solid Waste Act) “(5) The
term ``hazardous waste'' means a solid waste, or combination of solid wastes, which because of
its quantity, concentration, or physical, chemical, or infectious characteristics may--
(A) cause, or significantly contribute to an increase in mortality or an increase in serious
irreversible, or incapacitating reversible, illness; or
(B) pose a substantial present or potential hazard to human health or the environment when
improperly treated, stored, transported, or disposed of, or otherwise managed.”

7. The above documentation makes sludge  a very dangerous toxic pollutant according to the
CLEAN WATER ACT (CWA) “(13) The term ``toxic pollutant'' means those pollutants, or
combinations of pollutants, including disease-causing agents, which after discharge and upon
exposure, ingestion, inhalation or assimilation into any organism, either directly from the
environment or indirectly by ingestion through food chains, will, on the basis of information
available to the Administrator, cause death, disease, behavioral abnormalities, cancer, genetic
mutations, physiological malfunctions (including malfunctions in reproduction) or physical
deformations, in such organisms or their offspring.”

8. The above documentation makes sludge a very dangerous pollutant or contaminant
according to the
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND
LIABILITY ACT (CERCLA) (Superfund Act -SARA) which (33) “shall include, but not be limited to,
any element, substance, compound, or mixture, including disease-causing agents, which after
release into the environment and upon exposure, ingestion, inhalation, or assimilation into any
organism, either directly from the environment or indirectly by ingestion through food chains, will
or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer,
genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical
deformations, in such organisms or their offspring;”

9.  Part 503 is based on the Domestic Sewage Exclusion in the RCRA,  the Agricultural
Stormwater Runoff Exclusion in the CWA and the Exclusion for the Normal Application of
Fertilizer in the CERCLA.

10. According to
503.9(g) "Domestic sewage is waste and waste water from humans or
household operations that is discharged to or otherwise enters a treatment works." Hospital,
manufacturing, and slaughterhouse waste is not part of domestic sewage. Sludge from a
municipal treatment plant is always a solid waste until it gets to the farm and it is not a normal
application of fertilizer. It is in fact an RCRA Open Dump.

11. EPA documented twenty-five primary pathogens associated with a high incidence of disease
in the 1989 preamble to the part 503 sludge rule.
http://deadlydeceit.com/1989_503_pathogens.html

12. EPA documented  21 inorganic and organic carcinogenic pollutants in sludge proposed for
regulation but were ignored in the 1993 part 503 sludge rules.  Five of the admitted twenty-one
carcinogens in sludge are carcinogenic when inhaled in dust --
Arsenic, Beryllium, Cadmium,
Chromium IV and Nickel.
http://deadlydeceit.com/1989_503_cancer_list.html

13. In 1973, USDA’s John Walker reported to  EPA’s R.B. Smith and J. E. Smith Jr. that the pH of
limed sludge dropped within 30 days and they found Salmonella even at the highest lime levels.

14. In 1982,
EPA’s Mark Meckes, found antibiotic resistant genes were being transferred
between  bacteria in wastewater treatment plants and released to the environment in sludge and
recycled water. They are picked up by drinking water treatment plants. Other studies have also
confirmed his findings.

15. The result has been an
explosion of foodborne illnesses as documented by EPA and CDC
between 1986 and 1999. EPA documented 2 million cases of foodborne illness in 1986, while
CDC, Public Health Service and GAO estimated foodborne illnesses increased to over 76,
million cases by 1999. Today, CDC focuses on E. coli 0157 which was not a factor when the
sludge disposal program was created in 1981.

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