National Sludge Alliance
Charlotte Hartman, National Coordinator
180 Boston Corners Road
Millerton, NY 12546
(518) 329-2120 (phone/fax)

NSA Public Fact Sheet 135

Return to Sludge: Appomattox Beware!
Biosolids Collateral Damage - Ocean to Farm and Lawn


A recent editorial (Sludge bill would have empowered town residents, 3-15-03) in the Kennebec Journal, Morning Sentinel states, "These professionals many of whom are engineers, scientists and environmentalists  make a strong case that sludge spreading isn't merely an inexpensive approach to disposal, but one that leads to cleaner water, a cleaner  environment and an important source of income and fertilizer for farmers."

On the other hand, Lori Burkhammer of the Water Environment Federation (WEF, week of 3-3-03 Biosolids update ), blamed the continued use of sludge as a fertilizer on farmers when she posted the following statement on the National Biosolids Policy web site, "Some call it "sludge," others call it "biosolids fertilizer," and a number of people in Franklin County are calling for action. They are up in arms over a fertilizer manufactured from human waste, despite farmers insistence that's it's harmless."

However, dairy farmers who have had their farms and livelihoods destroyed by biosolds/sludge, Rune of Vermont, McElmurray of Georgia, Roller of Missouri, and Zander of Washington would disagree. Rune and McElmurry believed the EPA/WEF public relations (PR) statements that biosolids/sludge was safe. While Roller and Zander were part of the collateral damage from sludge site runoff. Arthritis, abortions, muscular problems started showing up in cattle following applications of sludge to land.

The EPA/WEF PR campaign to fool farmers and the public has not only infected dairy farms, it has infected the National Academy of Science in its two literature reviews of EPA furnished documents. It has also infected environmental science writers. As an example, the Eighth Edition of "Environmental Science" states that "Biosolids [is] organic material removed from sewage effluent in the course of treatment." It further confuses the issue when the writers also state, that biosolids was "Formerly referred to as sludge"

The EPA/WEF PR term, Biosolids, is used whether the sludge is 98% liquid, composted or heat dried. Furthermore, this scientific definition of "Biosolids" can not be reconciled with the part 503 which lists 9 toxic heavy metals.

The "Environmental Science" writers explain that a "Heavy metal [is] any of the high atomic-weight metals, such as lead, mercury, cadmium and zinc. All may be serious pollutants in water or soil because they are toxic in relatively low concentrations and they tend to bioaccumalate." In effect, they are a "Hazard [which is] anything that can cause (1) injury, disease, or death to humans, (2) damage to property, or (3) degradation of the environment."

How safe is this product of EPA/WEF's imagination known as biosolids? What treatment process removes all of the chemicals, including heavy metals, as well as the pathogenic disease causing agents?

By law, ocean dumping of toxic biosludge/sludge should have ceased December 31, 1981 in order to protect public health. Yet, ocean dumping continued for another nine years in the United States. When ocean dumping was stopped, the environmental laws required that sludge be properly disposed of in a sanitary landfill to protect public health.

Only very limited research to stop ocean dumping was completed at New York City dumping sites. Still, according to Senate Report No. 199-431, there were serious problems with ocean dumping of sludge at the 12 mile site off New York City and the same problems occurred when ocean dumping was moved to the 106 mile site. The adverse impacts at the site the report documented were:

Bacterial contamination and closure of shellfish areas; elevated levels of toxic metals and organohalogens in bottom sediments in and near the site including known fishing areas and within five nautical miles of coastal beaches; community changes (decreases) in relative abundance and diversity of species; sublethal toxicity effects in economically valuable species; bioaccumulation of certain metals and organohalogens in fish and shellfish.

Furthermore, according to the Senate Report:

"With the onset of large scale dumping of sewage sludge at the 106 mile site in 1987, fishermen began to complain of significant decreases in catches and incidences of diseased fish which were previously not found at these depths. Some of the diseased fish have a shell disease which is associated with sewage sludge and pollution in coastal waters. This disease was found around the 12 mile site. According to the Senate Report, "Scientists are just beginning to explore the impacts that sludge dumping may be having on marine resources in the area potentially effected by sludge dumping at the 12 mile site."

Ten years ago EPA outlined what we could expect as a result of ocean disposal. EPA wrote that, "In ocean disposal, certain pollutants often associated with municipal sludge, including mercury, cadmium, and polychlorinated biphenyls, can bioaccumulate. High levels of these pollutants can interfere with the reproductive systems of certain marine organisms, may produce toxic effects in aquatic life, or may present public health problems if individuals eat contaminated fish and shellfish." (FR. 58, 9259)

Mercury, Cadmium and PCBs as well as the rest of the heavy metals are listed by NIOSH as poisons as well as cancer causing chemicals. Mercury and Cadmium as well as the rest of the heavy metals listed in part 503 also causes genetic mutations. PCBs have also been shown to cause a number of serious non-cancer health effects in humans and animals, including effects on the nervous system of the developing fetus, the immune system, and the reproductive system.

Results of exposure may include developmental abnormalities.

The damage to our oceans reflect what we can expect to continue on land over the next 10 to 15 years even if we stopped biosolids/sludge dumping today. As the toxic pollutants continue to build up on our farmland as well as on our lawns and gardens, the epidemic of plagues will expand dramatically.

Recent published research reported by the Environmental News Service (ENS) show that all North Atlantic coastal shark populations have declined by 50 percent in the last 15 years. The greatest loss was for hammerheads, 89 percent have disappeared.

In 2003, New Jersey issued an advisory that "Infants, children, pregnant women, nursing mothers and women of childbearing age are considered to be at higher risk from contaminants in fish than members of the general public." The advisory warned that most fish in New Jersey should not be eaten at all by this high risk group and the general public should only eat one meal containing fish per year.

It's not any better on the west coast. The Environmental News Service recently reported that "California's attorney general has filed a lawsuit against five grocery store chains, aiming to require the stores to post warnings about the dangers of methyl mercury in fish" Attorney General Bill Lockyer said. "But consumers deserve to know when they are being exposed to chemicals that can cause cancer, birth defects and reproductive harm." "Dangerous levels of Methyl mercury have been found in swordfish, tile fish,shark or mackerel. Methyl mercury also causes nerve, heart and neurological systems damage and can lead to death."

EPA, USDA, CDC and FDA started promoting toxic heat dried sludge (which made some pathogens nondetectable) as a fertilizer on food crops over 20 years ago as Congress was enacting laws to protect us from the chemicals and disease causing organisms. This was a quick cheap fix for big cities who had to stop ocean dumping.. EPA wasn't worried about chemical contamination of farmers and the public. According to a recent quote by, "Bernard Goldstein, dean of the University Pittsburgh's Public Health School and former research chief for the Environmental Protection Agency in the 1980s. "It's a chemical era that we live in and there are trade-offs."

Tracing the cause and effect of health effects from toxic pollutants, especially chemicals and disease agents, spread through food, air and water can be almost impossible and a very expensive situation for the medical and scientific community. For many toxic pollutants there are no testing procedures and no safe levels. It would appear that the medical community has attempted to forestall a panic. Why else would "Abraham Mongantaler -- associate clinical professor at Harvard Medical School and director of men's health clinic in Boston --- (state) "Cancer is natural. Heart disease is natural. Arthritis is natural."

Congress enacted the environmental laws because these diseases caused by chemicals and pathogens were not natural. Yet, in 1985 EPA decided to take toxic levels of hazardous waste out from under the law and allow it to be spread on farmland as a fertilizer without warning farmers. That worked so well that by 1993, EPA allowed companies to dump toxic levels of hazardous substances into sewers, then promoted the use of this toxic soup generated by treatment plants as a safe, cheap fertilizer for farmers. EPA also promoted the marketing of this toxic soup as a fertilizer for lawns and gardens.

In 1989, due to the extreme amount of sludge generated, EPA specifically targeted farmers as hosts for the toxic pollutant contaminated waste (biosolids/sewage sludge) that had been destroying the ocean environment. Once EPA started promoting the use of composted and wet sludge as fertilizer, food poisoning incidents quickly reached 6.5 million cases annually in 1990. Still, at that time only about 4 percent of the dairy herds were contaminated with Salmonella. E.coli was not even an imagined threat.

Government agencies like EPA and USDA play the courts like a fine instrument.

When the agencies want to continue a policy that is detrimental to your health, they tend to lose critical lawsuits, which result in strange opinions that puts your life in jeopardy. As an example, that wonderful Mouth of the South, Molly Ivins, says, "Unless you have reason to suspect that your nearest and dearest are putting arsenic in your food, your bad stomach was likely caused by tainted meat." She said, "In December 2001, the Fifth Circuit Court of Appeals sided with the industry in a case that gutted meat and poultry inspection laws. 

In the Supreme Beef (I'm not responsible for the irony), the court ruled "because cooking kills Salmonella organisms, the presence in meat products does not render them injurious to health." Ivins says, "Industry officials have argued for years that food poisoning bacteria are natural constituents of raw meat and poultry and that they have no obligation to control them."

The reality is that cooking does not kill all pathogens or destroy the toxins they create which can cause your death. The numbers are not good. Out of approximately 180 million people in the United States, CDC says there are now 76 million cases of food poisoning annually, 325 thousand hospitalizations, and 5 thousand deaths annually from contaminated food. The 5,000 deaths annually are probably an extremely low estimate because CDC does not want to start a panic.

Salmonella is not the major problem anymore. In September 2002, the USDA research showed that 28 percent of the beef entering slaughterhouses is now contaminated with the untreatable deadly E. coli 157. That is an epidemic producing plague in anyone's book. But it gets worse. When doctors use antibiotics to kill E.coli, an even more deadly toxin is created. The treatment is a success, but the patient may die from E. coli produced toxins.

Writer Michael Weiss found meat is not the major culprit in food poisoning. He said, "A recent congressional study by the General Accounting Office (GAO) found that food poisonings in schools were growing at about 10 percent a year." Not only that, but "--- an estimated 85 percent of food poisoning comes from fruits, vegetables, seafood and cheese, according to the GAO."

According to Dr. David Swerdlow, a CDC epidemiologist, there were 15 reported deaths from E. coli between 1982 and 1992. By 1997, that figure had climbed to an estimated 200 to 250 deaths; 20,000 cases of E. coli-induced disease are reported every year in the United States. "It's one of the leading causes of kidney failure in kids," says Swerdlow."

In 1993, EPA pointed out that "Sludge disposed of in a sanitary landfill will not harm anyone, nor will it contaminate the food or water supply." (Federal Register (FR.) 58, 32, p. 9375).

Furthermore, EPA knew that when drugs, hormones, toxic chemicals, bacteria, viruses, parasitic worms and fungi are mixed and run through a treatment plant you get a deadly condensed soup known as sludge. You also get non-detectable drug resistant germs such as heat-resistant Salmonella, Listeria and E. coli spores in the treatment plant water and condensed residue (sludge) leaving the plant. Now Staph and Strep need to be considered.

In 1973, EPA was warned by USDA's John Walker that in the field, it takes about 30 days for the bacterial spores to dissolve and the germs become active again. There is no way to keep this toxic soup spread on crops out of our food chain. Even if corn was the only crop grown and it was used for ethanol production-- gluten is a byproduct of ethanol used in animal feed and human food.

Yet, EPA's Office of Water used the Clean Water Act (CWA) to put farmers and consumers health at risk under a policy for land disposal even though "The jurisdictional scope of the CWA is ``navigable waters," At EPA Office of Water's insistence, many states changed their solid waste laws to conform to the EPA's open dumping policy. This effectively transferred liability to the states because '' Congress recognized ``the primary responsibilities and rights of States to prevent, reduce, and eliminate pollution, to plan the development and use (including restoration, preservation, and enhancement) of land and water resources " In effect, the EPA has encouraged the states to change their laws to promote food and waterborne epidemics through pollution.-LSI-

Burkhammer, Lori, week of 3-3-03 Biosolids update (WORD):

Environment Science, Eighth Edition, Wright, Richard T. , Nebel, Bernard J., 2002, Prentice Hall

ENS, Lawsuit Warns of Methylmercury in Fish, Environmental News Service, January 27, 2003,

ENS, Engineered Corn Blamed for Pig Problems, Environmental News Service

ENS, Shark Fishing Quota Increases Called Illegal, Environmental News Service, January 27, 2003,

Ivins, Molly, Chicken about bad meat, The Kansas City Star, October 19, 2002, (p. B7) Opinion

Kennebec Journal, Morning Sentinel

Lazaroff, Cat , Shark Populations Plunge in North Atlantic, Environmental News Service, January 21, 2003,

USDA, E. coli in meat,

Weiss, Michael J., The new danger in the grocery aisle, Ladies Home Journal, November 2002, (p. 112--)