| http://www.desertdispatch.com/onset?db=desertdispatch& id=41&template=article.html Desert Dispatch [Alan Rubin's] Letters to the Editor February 20, 2007 - 3:01PM While biosolids have long been an integral component to the recycling industry, most folks tend to think of recycling in terms of bottles, aluminum cans or newspapers. Biosolids, which are derived from human sewage, is a topic most would rather just flush and forget. But biosolid management is a necessity and biosolid recycling is the environmentally preferred alternative. The challenges to biosolids recycling aren't a matter of safety or science; it's strictly a problem of perception. Disappointingly, much of the debate is based on emotions and feelings and not on science. Biosolids begin at the wastewater treatment facility where 95 percent of the pathogens are removed leaving just nutrient-rich material that is an effective and beneficial organic fertilizer. In fact 60 percent of biosolids in California are directly applied to crops. However, Nursery Products will add a margin of safety to this recycling activity by composting the biosolids. That means biosolids will be mixed with green material like wood chips and wood scraps from furniture manufacturers. During the composting process, the product heats up to 131 degrees for a minimum of 15 days killing off the remaining 5 percent of pathogens and viruses that possibly survived the wastewater treatment process. This results in compost that is 100 percent safe. In fact, this is the same compost sold in your local Home Depot or Lowe's garden department. Scientists have been studying biosolid recycling for decades and there is not one peer-reviewed study that shows evidence that this process poses any human health risk. Not one. There are open-air biosolid recycling facilities in more than 4,000 other communities throughout the United States that have operated safely and successfully for decades. Many of these facilities have neighbors much closer than eight miles yet there is no evidence of any health impacts to these communities. In fact, the open-air composting site in Austin, Texas, which has operated since 1989 is closer to downtown Austin than the Nursery Products site is to Hinkley. The Austin composting site is less than six miles from the University of Texas, Sixth Street, and even the State Capitol and Governor's Mansion downtown. Austin is one of the top tourist destinations in Texas and many of the Austin residents purchase the compost created at the site for their own gardening use. There is no evidence that any Austin residents or tourists have suffered any ill health effects and in fact the Longhorns football team won the college national championship in 2006 practicing and playing their home games within six miles of this biosolid composting site. This project is safe and this process is safe and will have no impact on Hinkley. Anyone who claims that biosolid recycling poses public health risks is using scare tactics and not science. Alan B. Rubin, Ph.D Dr. Rubin is an environmental consultant for Nursery Products and was the Environmental Protection Agency's (EPA) Chief of the Biosolids Risk-Assessment Branch. During his 28-year tenure at EPA, Dr. Rubin appeared as a federal government expert witness to testify in support of the Part 503 Standards that were developed to protect public health and the environment as they pertain to biosolids management. |
| Dr. Alan Rubin's February 20, 2007 letter to the editor would be funny if he wasn't the expert and knows better and likes to tell half truths sometimes. Biological solids in sewage are derived from human waste and industrial waste that pass through the sewage treatment process. Biological solids sludge management is mandated under the RCRA where it is listed as a solid waste. In spite of the laws, a few powerful people created a recycling program before most pollutants could even be identified. Since EPA has admitted there is absolutely no science or safety behind biosolids recycling, It is strange that Rubin would still be trying to change public perception just to justify wasting his life and destroying many more. Wastewater treatment does remove about 95 percent of the chemicals, pathogens (bacteria, viruses) and solids from sewage. These biological solids make up 1/2 to 4 percent of the sludge leaving the treatment plant. 60% of these biological solids are now directly applied to crops in California?. Some pathogens may be inactivated for a short time. Others are not affected. EPA has stated in the current Biosolids composting fact sheet that "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" What Rubin meant to say is that there is not one peer reviewed study that states the biological solids in sludge are safe for public exposure. EPA's own David Lewis had a peer reviewed published study showing health risks to real people. What Rubin meant to say was that since EPA and the state environmental departments approved these composting facilities, all agencies have refused to investigate any health complaints from the people in these communities. The agencies have betrayed their trust. Since 1986, food poisoning incidences have explode from 2 million to 76 million in 1999. But when we observe the big picture, Papillomavirus now infect 25 million female children and women. No one has any idea how many male children and men are infected even though CDC classified it as a sexually transmitted disease. Attention-Deficit/Hyperactivity Disorder (ADHD) among our children and adults has exploded and is now epidemic effecting 5-7-percent or more of our children -- and adults. The paramyxoviruses, which causes mumps and measles caused 745,000 deaths in 2001. Human Obesity is now epidemic. Autism is epidemic with 1 in 150 children effected. Acid refux disease is epidemic. Alzheimer's disease is epidemic. The we have the flesh eating bugs, Staph bug causes new (Necrotizing) pneumonia, Aspergillus Necrotizing pneumonia, Group A Strep Necrotizing pneumonia, E. Coli Necrotizing pneumonia, Yersinis pneumonia. Without immediate medical attention, life expectancy is from 72 hours to one week. EPA acknowledges that exposure to a pollutant (chemical, bacteria, virus, etc.) in biosolids/sludge through the air, water or 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 [people] or offspring [children] of the organisms [people]." FR. 58, 32, p. 9389 - part 503.9(t) Jim Bynum 17 year sludge researcher. Biosolids management is not addressed anywhere in the Part 503 Standards. "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." (FR. 58, p. 9252) www.deadlydeceit.com www.thewatchers.us |
| http://www.desertdispatch.com/common/printer/view.p hp?db=desertdispatch&id=259 ALAN RUBIN THREATENED ACTIVIST Time article, September 27, 1999 Response to Rubin's letter to Editor by Jim Bynum Letters to the Editor March 30, 2007 |
| Alan Rubin claims to have written the Part 503 sludge guidelines, which was based on exclusions in the laws, and published in February 1993. |
| Jim Bynum wrote the paper "Sludge Disposal: Sanitary Landfill-Open Dump-Superfund Site?" which was published by the New Mexico Environment Depart. in February 1993 |