Snyder, sludge fighter

Caroline Snyder Credit: COURTESY OF CAROLINE SNYDER It was sometime in the late 1990s that Caroline Snyder first read news reports about a couple in Greenland, NH, who were blaming recycled sewage sludge - also known as biosolids - for the death of their son. Although she was an environmental scientist, Snyder didn't really know anything about sludge, but the story piqued her interest because she had recently retired to New Hampshi

By | November 1, 2006

<figcaption>Caroline Snyder Credit: COURTESY OF CAROLINE SNYDER</figcaption>
Caroline Snyder Credit: COURTESY OF CAROLINE SNYDER

It was sometime in the late 1990s that Caroline Snyder first read news reports about a couple in Greenland, NH, who were blaming recycled sewage sludge - also known as biosolids - for the death of their son. Although she was an environmental scientist, Snyder didn't really know anything about sludge, but the story piqued her interest because she had recently retired to New Hampshire after 20 years of teaching at the Rochester Institute of Technology (RIT).

Snyder soon discovered that the US Congress had banned dumping sludge into the ocean in the late 1980s, and the Environmental Protection Agency had drafted new rules allowing such sludge to be used as fertilizer. Although she was experienced in environmental activism, sludge was something new to her, and different. At the time, she was working to draft a bill that would prohibit aerial pesticide spraying on timber, "but concern about pesticides is not really very controversial," Snyder writes in an E-mail. "It is shared by the scientific community and all major environmental groups. Concern about sludge issues, however, is very controversial."

Urged by a friend in the New Hampshire legislature who was concerned about sludge, Snyder decided to dig into the issue. At that time residents in several states were claiming that recycled sewage sludge was damaging their health, and a few scientists were voicing their concerns as well. (According to later press reports, the autopsy of the Greenland man was inconclusive, and a lawsuit against the biosolids company settled for an undisclosed amount before going to trial.) Much of the soil science world, however, and the EPA maintained that the practice was safe.

Snyder felt equipped to tackle the complexities of sludge: Her RIT classes had emphasized the political side of environmental science and looked at the influence of law, industry, and economics. As she scrutinized the EPA's policy on biosolids, Snyder concluded that there was "a terrible corporate influence over science." She founded Citizens for Sludge-Free Land and began speaking on behalf of the Sierra Club as a sludge expert.

Her argument against biosolids was fueled by several articles in Nature by David Lewis, an EPA scientist at the time, who criticized EPA policy. Subsequently, Lewis claims, the EPA drained his funds and squeezed him out of the agency. Lewis's whistleblowing story received media attention, and it also struck a chord with Snyder. "I find it abhorrent. I'm a naturalized citizen, a refugee from World War II. I know what happens in communist and fascist countries," she says. "The scientific community should be outraged that scientific whistleblowers are not getting protections they deserve."

As Lewis became bogged down with legal problems (see "The Plight of the Whistleblower," in the January 17, 2005, issue of The Scientist), Snyder stepped in to help. In 2002 she surprised his lawyer with a $50,000 check to cover his legal expenses. And as Lewis struggled to keep his research afloat, Snyder took over writing what had been a joint project to expose what they say is the EPA's unprotective sludge policy.

Lewis says the resulting paper, published in the October-December 2005 issue of the International Journal of Occupational and Environmental Health (IJOEH), is frequently quoted by lawmakers and sludge activists. (It had been cited only once in scientific journals tracked by ISI by mid-October of this year.) In it Snyder takes broad swipes at the EPA, claiming the agency forged an alliance with municipalities and sludge-management companies, whose "primary purpose was to control the flow of scientific information, manipulate public opinion, and cover up problems."

Lewis says Snyder was brave to enter the sludge arena, particularly in light of his own plight. But the response to Snyder's claims in her IJOEH article has "very gentlemanly," says the journal's editor, Joe LaDou. In May LaDou published a response from the Water Environment Federation (WEF) and the upcoming January issue will carry a letter from an EPA scientist. The WEF's letter states that "40 years of concerted research and experience with biosolids recycling have found 'negligible risk,' as a 1996 National Academy of Sciences review stated."

But Snyder won't be satisfied until the definitive safety study has been done. Until then, she intends to continue spending her retirement on the front lines of the sludge debate. For her, retirement is the perfect time to act boldly. "Very few scientists are willing to speak out. Somebody like me who has nothing to lose can speak out."

Comments

Avatar of: Dr Edo McGowan

Dr Edo McGowan

Posts: 19

November 15, 2006

Dr Snyder has justified cause to be seriously concerned, as do we all. Within EPA there is a distinct lack of recognition for issues relating to multi-drug resistant bacteria in land applied sewage sludge (biosolids). The accelerating risks from both antibiotic resistance and pandemic, especially as now found emerging in the world community, may be related to the disposal of inadequately treated sewage. On most continents, the practice of land applied sewer sludge has gained unprecedented acceptance based on a quick-fix to rapidly rid ourselves of waste. \n\nContrary to popular myth, many pathogens survive their passage through a sewer treatment plant thus, remaining to constitute an increased public health risk. Readily available scientific and medical literature is, and has been for some time, replete with data demonstrating and confirming this fact. Studies reported in the scientific and medical literature date back to at least 1970 showing failure of treatment. \n\nHowever, the issue has taken on aspects of a political and not a scientific argument. In the interim, most regulatory agencies have backed off. That this situation has continued for some time may be attributed, in part, to politics, economics, and the antiquated water quality standards, exactly Dr Snyder’s point. \n\nRecent papers in the scientific literature have noted the mixing of genetic material between various organisms provides for new types of pathogens and thus our immune systems may be faced with an unknown foe. Interestingly, much of this mixing goes on every day in sewage treatment plants in almost every city. Millions of gallons of effluent and tons of poorly treated sewage wastes are discharged to the environment and the solids, now termed biosolids are spread across thousands of square miles of farmland. There, this material is open to background organisms, thus allowing the intermixing with numerous species at the micro and macro biological levels.\n\nMany antibiotics or their metabolites pass through the body essentially unchanged. Thus feces and urine do contain some impressive levels. Kümmerer and others (1999, 2000, 2003, 2004), have followed this and have noted levels of antibiotics in sewage that are able to induce or maintain resistance. Added to this are the other materials dumped into the toilet or down the drain that confer resistance.\n\nBased on wastewater industry dogma and standards, released effluent and the land application of sewage sludge are benign and beneficial activities. If however, one reviews the current medical and scientific literature, a different picture emerges, one that raises serious questions about the benevolence of this activity and efficacy of the underlying standards. This leaves the citizens and patient base standing naked. \n\nDr Edo McGowan\n\n\n
Avatar of: Nancy F Holt

Nancy F Holt

Posts: 1

November 16, 2006

Without epidemiological studies to support human health safety from exposure to sewage sludge applied to farmland, how can the EPA and industry friendly scientists continue to support this method of waste disposal?\n\nWithout adequate testing of foods grown on sludge amended soils, how can the EPA and USDA continue to support a system that allows human foods to be consumed when they know heavy metals will become part of the foods, i.e., green leafy vegetables, potatoes, cereal grains, etc. \n\nSince there is no known way waste treatment plants can know or identity all potential toxicants in the sewage entering the WWTP, there is absolutely no scientific basis for limiting levels of harmful toxicants that are to be sprayed or spread on farmlands that grows our foods and exposes workers and rural neighborhoods from adverse health impacts.\n\nAll concerned scientists and citizens must ask why none of the six studies requested by the EPA Water Division ORD in the Preamble to the 40 CFR, Part 503 (Sludge Rule) in 1993 have never been performed. \n\nWe also must ask why the EPA has never initiated valid, independent epidemiological human health assessments to answer the many ongoing questions regarding human health and safety from sewage sludge.
Avatar of: Theresa Pimental

Theresa Pimental

Posts: 1

November 19, 2006

Dr. Snyder and Dr. Lewis' work in the area of sludge has greatly assisted exposed citizens. Their work is vital to the truth getting out there. We should all be appaulled when independent scientists and their research can be silenced by industry. \n\n The lies must stop for it is not the avian flu that will cause a pandemic, but sludge itself. The WEF's letter states that "40 years of concerted research and experience with biosolids recycling have found 'negligible risk,' as a 1996 National Academy of Sciences review stated"; is a deceitful statement. When one looks at the NAS report and is not skewed to the side of industry there are a great many serious concerns from a medical viewpoint. Following is my 2003 letter to the EPA in response to the NAS report:\n\nWe are writing to express our disgust with the EPA Sludge Rule. We are tired of hearing that human health and the environment are not at risk. I am Theresa Pimental of the Maine Sludge Alliance. As a Nurse Practitioner what I have seen in the field is appalling, but because there is no mandate for health assessments as a professional there is no avenue for solutions. \nA Class B site located behind the Benton Elementary School last fall made citizens up to 2 miles away ill. One individual suffered from a severe rash. A sludge spreading operation in Unity contaminated 5 wells, with the cost of the water filtering systems being born by elderly citizens. The Maine Sludge Alliance demands the EPA make the necessary changes as specified by the NRC, NAC, and the Presidential / Congressional Commission on Risk Assessments. \n Due to the insufficiency of the Part 503 rule, the EPA BIOSOLID PROGRAM IS OUT OF CONTROL AND CAUSING IRREPARABLE DAMAGE TO HUMAN HEALTH AND THE ENVIRONMENT! The Data Gaps found are so substantial that as a medical professional I must say the EPA has opened avenues of contamination and disease in the United States. \nThe Maine Sludge Alliance quotes the following from the NAC / NRC REPORT BIOSOLIDS APPLIED TO LAND: ADVANCING STANDARDS AND PRACTICES that show the Data Gaps: \n\n1) ?EVALUATION OF EPA's APPROACH TO SETTING CHEMICAL STANDARDS? (Page 177)\nSome pollutants and exposure pathways were eliminated in the screening processes and risk assessments when chemical-specific data were insufficient to perform pathway-specific calculations or when toxicity data were insufficient for a given pollutant. For example, a plant uptake factor for lindane was not available, so no assessments were conducted for any pathway that relied on that factor. The technical support documents for EPA?s Round 1 and Round 2 assessments do not provide a list of data gaps, nor do they specify the chemicals and pathways that were eliminated from consideration because of data gaps. Lack of information does not equate to lack of risk. THEREFORE, DATA GAPS SHOULD NOT BE USED AS CRITERION FOR ELIMINATING CHEMICALS FROM CONSIDERATION BUT USED TO IDENTIFY IMPORTANT AREAS FOR FUTURE RESEARCH.\n\n2) ?ADVANCES IN RISK ASSESSMENTS? (Page 156)\nOf particular note are updates to the risk-assessment framework recommended by the NRC, the Presidential/ Congressional Commission on Risk Assessment, and various EPA offices. The risk-assessment methods and policies practiced and advocated at EPA have changed significantly, although not at the pace recommended by the NRC and the risk commission. As a result, the Part 503 rule, which has not been modified to account for any new methods and policies, is now inconsistent with current NRC recommendations and EPA policies within various offices.\n\n3) ?EVALUATION OF EPA's APPROACH TO SETTING PATHOGEN STANDARDS? (Page 304)\nBecause there are no requirements for on-site monitoring of pathogens, there is little information available to evaluate the reliability of use restrictions in achieving their intended minimum exposure levels or to verify that those desired levels are maintained over an extended time. The committee found that some potential exposure pathways were not sufficiently considered when the use restrictions were developed. For example, potential off-site inhalation of dust and aerosols does not appear to have been considered. The potential for groundwater contamination by pathogens was not sufficiently addressed. In addition, the potential for runoff to contaminate surface waters was not adequately addressed.\n\n4) ?INTEGRATION OF CHEMICAL AND PATHOGEN RISK ASSESSMENT? (Page 331 and 332)\nThe committee found that although the chemical-specific risk assessments conducted to establish Part 503 regulations can be improved by using new risk-assessment methodology, the remaining uncertainty for complex mixtures of chemicals and biological agents is sufficient to preclude the development of risk-management procedures that can reliably result in acceptable levels of risk. In reviewing these methods, the committee found that there are inherent differences between chemical and pathogenic agents that must be considered in single-agent risk assessments. In particular, infection of an individual from exposure to pathogens in biosolids might result in secondary infections in others. The secondary infections might be caused by person-to-person contact or transmission of the pathogen to others through air, food, or water.\n\n The Maine Sludge Alliance demands that the Findings and Recommendations of the NRC/NAC as follows be immediately incorporated into the Part 503 rule and implemented.\n\nOverarching Findings (Page 4) To assure the public and to protect public health, there is a critical need to update the scientific basis of the rule to (1) ensure that the chemical and pathogen standards are supported by current scientific data and risk -assessment methods, 2) demonstrate effective enforcement of the Part 503 rule, and (3) validate the effectiveness of biosolids-management practices.\n\nOverarching Recommendations (Page 4)\n*Use improved risk-assessment methods to better establish standards for chemicals and pathogens. \n*Conduct a new national survey of chemicals and pathogens in sewage sludge. \n*Establish a framework for an approach to implement human health investigations.\n\n
Avatar of: Ned Beecher

Ned Beecher

Posts: 1

December 6, 2006

Ned Beecher\nExecutive Director\nNorth East Biosolids and Residuals Association (NEBRA)\n\nDecember 6, 2006\n\nKerry Grens? article about activist Caroline Snyder, PhD, ?sludge fighter,? is a fair and balanced piece of writing in and of itself. While it generates interest in and empathy for Dr. Snyder, it takes care not to endorse her claims. For an article in a science journal, that?s a good thing - because Dr. Snyder?s claims are not based on a fair evaluation of the complete body of scientific literature regarding the management of treated sewage sludge or ?biosolids.?\n\nDr. Snyder?s thinking is well represented in a 2006 paper in the peer-reviewed International Journal of Occupational and Environmental Health (IJOEH). The Scientist?s Ms. Grens accurately portrays the paper as ?claiming the agency [EPA] forged an alliance with municipalities and sludge-management companies, whose ?primary purpose was to control the flow of scientific information, manipulate public opinion, and cover up problems.? While Ms. Grens withholds judgment about these claims of conspiracy, there are plenty of knowledgeable professionals in the water quality field who have rebutted them. For example, the Water Environment Federation, which represents tens of thousands of wastewater operators and engineers, said in a published letter to IJOEH: ?In short, Dr. Snyder's paper reports no new scientific research. Underpinning her arguments are rare incidents of alleged harm caused by biosolids - rare as compared to thousands of successful, beneficial biosolids recycling projects. The alleged incidents of harm were reviewed by independent authorities closer to the events in time and space. Those reviews reached conclusions different from those reached by Dr. Snyder. The assumptions underlying the paper?s hypothesis are unsupported. An alternate conclusion to the disparate, selected events and statements compiled by Dr. Snyder is that Congress, most state and federal regulatory agencies, most public wastewater treatment facilities, many private company personnel, and most researchers agree with the National Academy review panels that recycling biosolids to soils, while worthy of continued scrutiny and ever-improving practices, presents negligible risk.?\n\nFor ten years, Dr. Snyder has argued against applying treated sewage sludge/biosolids as fertilizers and soil amendments. She has argued that the federal USEPA 40 CFR Part 503 regulations, adopted in 1993, ?are not based on sound science.? The vast body of experience and literature demonstrates otherwise.\n\nThe use and disposal of biosolids are governed in the U. S. by the federal ?Part 503? rule and state regulations (which, in most states, are built on Part 503, but are considerably more stringent and comprehensive). The development of the Part 503 rules involved a comprehensive review of decades of experience with treated sewage sludge use and thousands of scientific studies by university and government researchers from around the nation. Considerable scientific data and talent ? headed by a team of twelve researchers with over 300 combined years of training and research experience, including faculty of the Universities of Alabama, California, Colorado, Cornell, Florida, Ohio State, and Washington and researchers from USDA and USEPA ? were assembled and used to structure the final rule. Peer reviews were conducted by additional experts and the agency?s Science Advisory Board. At the time, the 503 rule was considered by USEPA scientists to be the most thoroughly researched regulation ever promulgated by the agency. \n\nBut, because the management of sewage sludge/biosolids has always created some controversy (it?s a natural reaction to question putting something produced from human waste on soils to grow crops), USEPA has twice requested reviews of the Part 503 program by National Research Council (NRC) review panels of the National Academy of Sciences. In a 1996 review of biosolids and reclaimed water use on food crops, an NRC panel of scientists selected for their relevant expertise and experience found, in summary: ?While no disposal or reuse option can guarantee complete safety, the use of these materials in the production of crops for human consumption, when practiced in accordance with existing federal guidelines and regulations, presents negligible risks to the consumer, to crop production, and to the environment? (National Academy of Sciences: Use of Reclaimed Water and Sludge in Food Crop Production, 1996). \n\nIn 2002, another NRC panel focused on ?identifying how current risk-assessment practices and knowledge regarding chemicals and pathogens in biosolids can be used to update and strengthen the scientific basis and credibility of EPA?s biosolids regulations? (National Academy of Sciences: Biosolids Applied to Land: Advancing Standards and Practices, 2002). The ?overarching findings? were: ?There is no documented scientific evidence that the Part 503 rule has failed to protect public health. However, additional scientific work is needed to reduce persistent uncertainty about the potential for adverse human health effects from exposure to biosolids? (see note 1, below). \n\nTo further emphasize the breadth and depth of the scientific basis of current treated sewage sludge/biosolids management, consider this: every ten years since 1973, scientists involved in primary, direct research on the land application of biosolids and other residuals (e.g. animal manures) have held a major conference to review the state of the science in this field and identify future research priorities. The most recent such conference was held in January, 2004, and many of the papers presented were published in the Journal of Environmental Quality in January, 2005. While focusing on current questions and research needs, the conference summary paper states: ?The design, guidance, regulations, and management practices currently employed by modern sustainable land application projects have evolved from many years of research and demonstration efforts as well as experience with both pilot- and field-scale projects. Such efforts have demonstrated the beneficial and sustainable use of residuals on productive farmland, forests, marginal lands, drastically disturbed areas, and even highly contaminated sites? (O?Connor et al., 2005: Sustainable land application: An overview. Journal of Environmental Quality, 34:1).\n\nAll of these reviews have been conducted by independent, diverse, trained, and working research scientists from a variety of scientific specialties, including the soil and agricultural sciences, water quality and wastewater engineering, related environmental sciences, chemistry, food sciences, and public health. They hail from not only U. S. universities and research institutions, but from around the world. \n\nIn comparison, Dr. Snyder, who holds an A.B. in Germanic Languages and a Ph.D in Germanic Languages and Literature, cites a small number of published peer reviewed papers and points to media accounts, gray literature, and undocumented allegations to bolster her arguments against the application to soils of treated sewage sludge/biosolids ? even though she consistently stresses the importance of ?sound science? and urges reference to peer reviewed scientific papers (see note 2, below). As with any other commenter, her views should be accorded appropriate weight in relation to the scientific literature she cites and her specific expertise.\n\nIn The Scientist, Ms. Grens? wrote: ?As she scrutinized the EPA's policy on biosolids, Snyder concluded that there was "a terrible corporate influence over science." This is an extraordinary claim. USEPA, USDA, USFDA, independent university researchers, state environmental and agricultural agencies, and hundreds of municipal governments ? all of which are publicly funded ? are the ones involved in setting policies that allow ? and, in many cases, encourage ? the recycling of properly treated and tested sewage sludge/biosolids to soils. Managing sewage sludge is a public function. The fact that corporations are involved is because public agencies contract with the private sector for goods and services and have, in some cases decided to apply biosolids to soils with the help of a private contractor ? as is the case with many public functions (e.g. building roads). (See note 4, below.)\n\nSewage sludge must be managed, because it is a necessary by-product of protecting water quality. There are many significant environmental benefits when a wastewater treatment facility?s treated sewage sludge/biosolids are applied to soils (in accordance with state and federal regulations) as close as practicable to the facility, to improve soils and crop yields. Such utilization of a local source of macro- and micro-nutrients, moisture, and organic matter ? replacing the need for a significant amount of imported chemical fertilizer ? is often the best option in terms of conservation of energy and resources. Not all sewage sludges meet state and federal standards and can be recycled to soils; but many do and should be.\n\n-------\nNed Beecher has an MS in Resource Management and Administration (Antioch Univ.) and a BA in Geology (Amherst College). He is Executive Director of the small, not-for-profit professional membership organization, North East Biosolids and Residuals Association (www.nebiosolids.org), which advocates for the environmentally sound recycling of biosolids and other organic residuals in New England and eastern Canada. In this role, he is involved in administration, membership services, information sharing, training, policy, policy research, and working with the public and media.\n----------\n\nNotes:\n1. As Chair of the 2002 NRC panel Thomas A. Burke, Ph.D. and professor at the Bloomberg School of Public Health, Johns Hopkins University, noted, "the consensus report called on EPA to update the scientific basis of its requirements, to improve our knowledge about chemicals and disease-causing pathogens that may be present in biosolids, to evaluate concerns about health effects and exposure, and to make a stronger investment in the agency programs overseeing biosolids application and management.... [W]e found no evidence of an urgent public health risk from exposure to land-applied biosolids, based on our review of the scientific literature.... EPA's biosolids regulatory program must move forward, as should any regulatory program that has been in place for a number of years. The good news is that better scientific tools are available now to help EPA gather needed data and monitor land-application practices. Science does not remain static, nor should our efforts to protect public health and the environment." \n\nSince the report was released, EPA has been conducting work in accordance with its recommendations, to the extent possible based on available funding. Additional independent research continues at USDA, at the Water Environment Research Foundation (www.werf.org), and at universities across the continent and around the world, resulting in scores of published papers each year. While some research continues to raise questions about particular aspects of biosolids? potential impacts, other research continues to find that some newer concerns are not as significant as once thought (e.g. some chemicals that appear in biosolids from personal care products and pharmaceuticals have been found to degrade rapidly in soils). In short, the science continues to advance. At the same time, the ongoing experiences of thousands of biosolids recycling programs continue to show that the practice has measurable benefits to soils, crops, and ecosystems (farmers choose to use biosolids!) while presenting no apparent significant risk. Those of us involved in biosolids management continue to monitor the scientific developments, and best management practices are improved as warranted.\n\n2. See the introduction to Dr. Snyder?s website, http://www.sludgefacts.org; the site includes mention of a small number of selected peer reviewed published papers and only one of the large-scale reviews by diverse scientists discussed above. \n\nDr. Snyder is founder and head of ?Citizens for Sludge-Free Land,? a non-profit organization registered in New Hampshire. Neither Dr. Snyder, nor her lobbyist, has provided information about the organization?s membership numbers, financing, or other details when asked by NH legislators during public hearings. In the past, Dr. Snyder has also stated that she represents ?Citizens for a Future New Hampshire? ¬? another small group, formed in the mid-1990s, registered in NH, and for which there are also few public details ? as well as the NH chapter of the Sierra Club (where she was the sludge committee chair for several years and, as of 2006, is a member of the NH Chapter?s Executive Committee).\n\nDr. Snyder is a professor emeritus of Rochester Institute of Technology, where she taught for many years in the College of Liberal Arts. According to the RIT website (www.rit.edu) the College of Liberal Arts ?serves RIT in three ways. First, the college provides a required curriculum in general education for all candidates for baccalaureate and associate degrees; second, the college offers six undergraduate degree programs and two graduate degree programs, and third, the college provides opportunities for RIT students and the RIT community to participate in cultural experiences of theater, music, creative writing, public speaking, and special lecture series.? For comparison, most of RIT?s degree programs are in science and technology ? separate departments from the College of Liberal Arts ? and include: Applied Science & Technology, Computing & Information Sciences, Imaging Arts & Sciences, Business, Engineering, and Science; within these disciplines well over 100 undergraduate science degrees are offered.\n\n4. The fact is, private corporations may well be more likely to benefit from high-tech disposal and energy production methods espoused by Dr. Snyder (see below) than from the often simpler systems of land application, composting, and other forms of recycling to soils. But it is important to note that current high technologies for recovering energy from sewage sludge have not been clearly demonstrated to offer net energy benefit, especially when all treatment, transport, and dewatering energy costs are included.\n\nHere is an April 2005 email correspondence from Dr. Snyder to U.S. Composting Council?s Compost listserv (with a copy to the corporation Thermoenergy): \n?Unless and until those who authored the 503 rule and those who are still defending the 503s admit that the current US land application policies reflect regulatory failure at the highest level, and unless EPA, industry, their lobbying groups, their gatekeeper scientists, and state agencies admit that there has been an organized denial and cover-up of all the problems that have been reported and documented since 1993--industry, regulatory agencies, and Congress will have no incentive to explore better solutions.\n\n?One new and promising solution is to turn sludge into fuel (e.g. www.thermoenergy.com). Meanwhile, short term measures to reduce risks include placing dewatered sludges in state-of-the-art landfills, and using sludge as landfill cover. Several studies have shown that land filling is actually less expensive than land application.\n\n?Finally, until better solutions are promulgated, this contaminated waste material must be disposed of in such a way that it does not impact rural neighbors, live stock, groundwater, food crops, or cause long-term degradation of healthy agricultural soils.\n\n?Caroline Snyder, Ph.D.?\n\n--------------\n

December 22, 2006

\n\n\n\n \n\n \n\n \n\n\nMr. Beecher defends EPA?s 503 sludge rule, which failed to pass EPA?s own internal scientific peer review in the Office of Research & Development (ORD) in 1992(1). He disparages my credentials at the Rochester Institute of Technology, where I designed and taught environmental science and related courses(2), and he falsely claims that Citizens for Sludge-Free Land (CFSL) is withholding information concerning its funding sources and membership.\n\nCFSL is not a membership organization. It is a state-chartered, nonprofit group of volunteers whose stated purpose is ?to provide scientific information concerning public health and environmental risks associated with land applying recycled waste products, including processed sewage sludge (biosolids) containing potentially hazardous chemical and biological wastes.? The group advocates ?regulatory reform that protects public health, agriculture, and the environment.? CFSL?s website, www.sludgefacts.org, provides links to peer-reviewed scientific articles, government documents, and other technical information that is often omitted from government and industry-supported websites, such as the website for Mr. Beecher?s organization.\n\nCFSL volunteers individually cover most of their own expenses. To date, the group has received two small grants from the New England Grassroots Environmental Fund, totaling $3,500, none of which was used for lobbying. Additionally, the Sierra Club provided CSFL with $500 to cover the costs of copying and mailing its policy documents to New Hampshire towns needing assistance in drafting local sludge ordinances. These documents are available at www.sierraclub.org/policy/conservation/solidswaste.asp.\n\nMr. Beecher describes his organization, the Northeast Biosolids and Residuals Association (NEBRA), as a ?small? not-for-profit group. NEBRA, in fact, is nationally supported by EPA?s Office of Water and the Water Environment Federation (WEF), the wastewater industry?s main lobbying organization. Its purpose is to defend EPA?s and the industry?s position that current land application practices are safe, beneficial, sustainable, and scientifically sound. \n\nNEBRA has historically functioned as an important outlet for EPA and the WEF to disseminate false, incomplete, and misleading information whenever scientists conclude that sewage sludge has harmed public health or the environment. EPA?s Office of Inspector General, for example, investigated false and misleading information concerning Dr. David Lewis that was publicly disseminated by Dr. John Walker in EPA?s Office of Water. Walker was one of the authors of the 503 Sludge Rule. The information was published on NEBRA?s website, which was funded by Walker. When the Inspector General and EPA?s Office of General Counsel found that the information was false, Walker was ordered to inform NEBRA to include a disclaimer stating that its website does not represent EPA?s position. To stop Walker and other Office of Water officials from disseminating false information about his research at EPA and the University of Georgia, Dr. Lewis filed suit against the EPA .\n\nLewis, a senior-level research microbiologist in EPA?s Office of Research & Development, was terminated by EPA in 2003 after he published peer-reviewed scientific articles in Nature and other leading science and medical journals documenting problems with land application of sewage sludge, including illnesses and deaths among humans and animals. Although the papers by Lewis and his coauthors were referenced and discussed in draft versions of the National Academy of Sciences report cited by Mr. Beecher, the committee chair, Dr. Thomas Burke, deleted the papers in the final version of the report when Wisconsin Biolsolids Coordinator Greg Kester e-mailed Burke in 2002 and advised him not to elevate Dr. Lewis? work because it was critical of EPA (3).\n\nBeecher claims that the IJOEH paper does not represent the views of any qualified scientists. However, as I pointed out in the paper, the work was a joint effort between Dr. Lewis and myself. It is thoroughly documented and has never been refuted in any peer reviewed scientific article. Beecher?s disparaging remarks about the authorship represent his continued efforts to publish false and misleading information about any scientists, including Dr. Lewis, who have reported problems associated with land application of sewage sludge.\n\nFor over thirty years, the internationally renown Cornell Waste Management Institute has published peer-reviewed scientific articles revealing gaps in the science underpinning EPA?s sludge regulations (4). Moreover, serious concerns about the safety of current land application practices have also been raised by the Sierra Club, (5) the National Farmers Union (6), leading producers of food products, (7) and 73 environmental, health, and farm organizations who petitioned EPA in 2000 to place a moratorium on the land application of sewage sludges.\n\nHundreds of rural residents, including those suffering from serious adverse health problems linked to sludge exposure, have appealed to their local, state, and national agencies to revise the rules or to stop the practice. What they are experiencing and reporting are not ?rare incidents of alleged harm? as Beecher claims. In fact, Helane Shields has collected 500 pages of articles and investigative reports about adverse effects from land application that have occurred since 1993(8). In 1997, Shields filed a FOIA request with EPA for information about sludge incidents documented in agency files. On October 30, 1997, Dr. Alan Rubin telephoned Shields and told her that EPA had on file ?thousands of allegations of problems? and that it would cost her $42,000 to obtain copies (9). \n\nYet, the overarching goal of EPA?s Office of Water and the organizations it funds, such as NEBRA, is to continue to defend an illusion that the 503 Sludge Rule has never failed to protect public health or the environment. EPA funds the University of Georgia, the University of Arizona?s NSF-based Water Quality Center, and other academic institutions to publish papers designed to cover up problems with the 503 Sludge Rule. At the same time, EPA diligently works to discredit and eliminate from the workforce scientists who are involved in documenting the problems. This approach, which is scientifically dishonest and completely disregards the public interest, will not forever sustain the illusion of safety. \n\nNotes\n\n\n(1) ?We did not think the (503) rule passed scientific muster. If the sludge rule were put to the test today, it would miserably fail EPA?s own scientific peer review process.? Sworn statement by Robert Swank, Jr., former research director at EPA?s Office of Research and Development laboratory at Athens, GA. Cited in Snyder C. The dirty work of promoting ?recycling? of America?s Sewage Sludge. (2005) IJOEH, page 417. Subsequent citations to IJOEH refer to this paper. \n\n(2) The mission of Rochester Institute of Technology?s (RIT) College of Liberal Arts is to bridge the gap between the humanities and the sciences, ? to produce graduates that can balance an understanding of science and technology with social considerations.? The faculty includes several scientists. One of its roles is to make future engineers and scientists aware of the ethical, environmental, and social impacts of their respective fields, so that they ?develop a critical awareness of the interaction among people, science, technology, and the environment.? \n\nTo that end, the College of Liberal Arts offers interdisciplinary undergraduate and graduate degree programs in Science, Technology, and Public Policy. ?It is this grounding in humanistic values combined with technology and science that makes these programs both balanced and unique.?< www.rit.edu/~ppolicy/>\n \nBeginning in 1969, I designed and taught such interdisciplinary courses, focusing on environmental policy. In 1991, I was appointed the chair of the College?s Department of Science, Technology, and Society. \n \n(3) The 2002 National Academy of Science report also warned ?treated sewage sludge is such a complex and unpredictable mix of biological and chemical wastes that its risks, when used for farming, can not be reliably assessed. Therefore, standard strategies to manage the risks of land application do not protect public health.? IJOEH p 415.\n\n(4) ?Current US federal regulations governing the land application of sewage sludges do not appear adequately protective of human health, agricultural productivity, or ecological health.? Harrison EZ, McBride MB, Bouldin DR. Land application of sewage sludges: an appraisal of the US regulations. Int J Environ Pollution. 1999; 11: 1-36. \n\n(5) ?The Sierra Club opposes the land application of municipal sewage sludges as a fertilizer and/or soil amendment because the current policies and regulations governing this practice are not adequately protective of human health and the environment.? < www.sierraclub.org/ppolicy/conservation/solidwaste.asp>\n\n(6) ?The current practice of spreading hazardous wastes and Class B biosolids on land surfaces . . . should be discontinued (to) protect the soil and water of agricultural lands from which the nation?s food is produced.? 2004 Policy Statement, IJOEH p.425.\n\n(7) ?The risk of utilizing municipal sewage sludge . . . is not a health risk which we need to take. This is not a publicity statement since it is rigorously enforced and we have at times dropped suppliers who have used sludge on their crop land.? Statement by J.M Dryer, General Manager of Heinz? Food & Technology Systems, IJOEH page 424.\n\n(8) Available from Helane Shields hshields@worldpath.net\n\n(9) IJOEH p. 418.\n

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