A CAVEAT FOR FARMERS, FOR INSURERS, FOR BANKS WHICH HOLD THE MORTGAGES ON FARMS, AND for
SUBSEQUENT BUYERS OF THE SLUDGED FARM LAND
MYTH: “’Fertilizing’ with sewage sludge biosolids increases yields.”
Actually lime decreases yields, and so does repeated sludging. It is the water in sludge that causes crop growth, but
the “go-along” chemicals increase toxic inorganic and organic pollutants in the soil and leaching of polluting nitrates to
ground water and phosphorus to surface waters. Class A sludge has so little nitrogen that huge amounts have to be
applied to reach the agronomic rate for nitrogen, which again results in heavy application of toxic chemicals,
radioactivity, etc. in the sewage biosolids.
OFFICIAL US EPA POLICY IS TO DISPOSE OF LEACHATES FROM LANDFILLS AND SUPERFUND SITES IN LOCAL
POTWs (publicly owned sewage treatment plants) where the wastewater treatment process reconcentrates
the chemicals and radioactivity in the sewage sludge biosolids which is spread on agricultural land in Rural
America. One of the more egregious cases involves plutonium-laced wastes from the Lowry Landfill
Superfund Site which are discharged to Denver Metro POTW with the resultant sludge spread on Denver-
owned wheat fields.
http://www.epa.gov/superfund/sites/fiveyear/f01-08003.pdf
PAGE 249 - 250 OF 398 Some really biting quotes from Colorado farmers on Lowry Landfill Superfund Site
wastes to Denver Metro, and from there the sludge biosolids being spread on fields . . . . public perception
of contaminated agricultural products . . .
"Strapping Superfund cleanup onto farmers' backs could drive more family farms out of business."
"The farmers are not being respected. The farmers have the backing of the Colorado Farm Bureau, the
Cattlemen's Association and the Soil Conservation Districts. They have asked the Elbert County
Commissioners to fight the decision to send Lowry waste to Metro and have done a good job in keeping it out
of papers. They have the support of the farm community. The perception that there may be plutonium in
the biosolids from the Lowry water could negatively impact the entire farming community."
"Metro and EPA's scientists did work to study the problem and left the farmers out of the process, and now
the farmers area bearing the brunt of the problem."
page 251 - heavy winds . . . . lots of dust . . . "increase in dust and air pollution and water runoff downgradiant of
Metro's farm. Biosolids are leaving the Metro site. " . . . Metro uses poor farming practices . . . . this is
probably the worst case of wind erosion in the United States . . . . .
". . . Superfund materials should not be moved to another area and spread on 52,000 acres of the most erodable soil in
the United States."
***********************************************************************************************************
RADIOACTIVE SEWAGE SLUDGE ON COW PASTURES IN FLORIDA – LAWSUIT ON BEHALF OF VICTIMS:
http://www.palmbeachpost.com/pbccentral/content/local_news/epaper/2006/01/14/m1a_slfpl_0114.html
Judge rules in favor of FPL in suit over nuke plant
By Sarah Prohaska
Palm Beach Post Staff Writer
Saturday, January 14, 2006
Two sets of Treasure Coast parents — who blame emissions from Florida Power & Light's nuclear power
plant for their sons' rare cancers — won't get to present their cases to a jury this month after a federal
judge ruled in favor of FPL.
“They point to documents their attorneys dug up from the early 1980s detailing the release of
sewage sludge that was accidentally contaminated with radioactive waste in the late 1970s and
early 1980s. The waste from a contaminated sink was mistakenly shipped to a cow pasture near
Glades Cut-Off Road in western St. Lucie County, and also to the Fort Pierce Sewage Treatment
plant, the plaintiffs argued. FPL and the families disagreed on the amount of contamination.”
“Throughout the litigation, the families' attorneys complained that FPL did not produce documents about
the incident on time, and Cohn in his ruling acknowledged that "certain plant records regarding three days
in mid-September 1982, when the sludge incident was first discovered, remain missing and were perhaps
destroyed long before this case began."
**************************************************************
DIOXINS IN SLUDGE – see page 9 hereof . . . soils at risk for permanent contamination:
“If regulations change to meet the perceived risks stated in the dioxin study, soils receiving application of
sludge with dioxin levels above background are at risk of being permanently taken out of production in the
future.”
*****************************************************************************************************
THE EPA RECOMMENDED INDEMNIFICATION AGREEMENT WHICH FARMERS SHOULD GET BEFORE ALLOWING
SEWAGE SLUDGE BIOSOLIDS TO BE DUMPED ON THEIR LAND:
http://www.epa.gov/owm/mtb/biosolids/503pe/503pe_2.pdf (Go to "page 28 of 32" . . . . . it is page 52 of the actual
document . . . . .
[I have asked many sludge farmers if they ever got this indemnification agreement, and every one of them
said “no” !!]
Page 52 of US EPA Plain English Guide to Biosolids:
EPA recommended agreement between a landowner and the sludge spreader:
"Contractor agrees to indemnify, defend, and hold harmless
(Landowner/Leaseholder) from and against any and all claims, suits,
actions, demands, losses, costs, liabilities, and expenses (including remediation
costs and reasonable attorney's fees to the extent such losses results from:
(1) Contractor's or Generator/Preparer's violation of applicable
laws or regulations in effect at the time of biosolids application; or
(2) the negligence or willful misconduct of Contractor in delivery and application of biosolids to the undersigned
Landowner/Leaseholders’ property.
In the event this indemnification is enforced against the Contractor for a violation of law by a Generator/Preparer,
Landowner/Leaseholder agrees to assign and subrogate to Contractor its claim against Generator/Preparer.
This indemnification shall survive termination of this Agreement
until the expiration of any applicable statutes of limitations.
Landowner/Leasehold shall promptly notify Contractor in the event of
a third-party claim and Contractor shall have the right to provide and
oversee the defense of such claim and enter into any settlement of such claim at
its discretion (holding the Landowner/Leaseholder harmless). Landowner/Leaseholder agrees to fully cooperate with
Contractor in the defense against any third-party claim."
************************************************************************
http://cwmi.css.cornell.edu/Sludge/dairysludge.pdf Page “21 of 23”
AND HERE IS THE INDEMNIFICATION AGREEMENT WHICH CORNELL WASTE MANAGEMENT INSTITUTE, ITHACA,
NEW YORK, RECOMMENDS THAT FARMERS GET:
[Indemnification agreements may provide some protection for farmers. One such agreement suggested by
a municipality is:
"______________________________________(insert City, Sanitation District or other POTW) as Waste
Generator and ______________________________________(insert Waste Hauler, Applicator, etc.) as Waste
Contractor jointly and severally agree to fully indemnify, defend and hold harmless
_________________________________Landowner, and ___________________________________________,
Leaseholder, from and against any and all claims, suits, actions, demands, losses, costs, liabilities and
expenses, including remediation costs and reasonable attorney's fees arising out of, or resulting from, or
in any way relating to the actions of Waste Generator or Waste Contractor or their employees, agents or
contractors, including without limitation the processing, hauling, depositing and spreading of biosolids on
the lands of Landowner or Leaseholder regardless of the active or passive negligence of Landowner or
Leaseholder excepting only such injury or harm caused by the sole negligence or willful misconduct of
indemnified party.
The parties intend that this indemnity shall extend as broadly as legally permitted and shall apply
regardless of whether the loss results from the negligence of the indemnified party or any other cause,
except for the sole negligence or willful misconduct of the indemnified party. This agreement shall
survive the termination of this agreement and shall run with the land extending to subsequent landowners
and leaseholders of the affected land.
Waste Generator and Waste Contractor further jointly and severally represent and warrant that the
biosolids and the actions pertaining thereto including without limitation the processing, hauling, depositing
and spreading are not harmful to land, water, fish, wildlife, plant life or humans. This representation and
warranty shall survive the termination of this agreement and shall run with the land extending to
subsequent landowners and leaseholders of the affected lands."
http://findarticles.com/p/articles/mi_qa3816/is_199907/ai_n8832578/pg_1
Unsafe sewage sludge or beneficial biosolids?: Liability, planning, and management issues regarding the
land application of sewage treatment residuals
Boston College Environmental Affairs Law Review, Summer 1999 by Goldfarb, William, Krogmann, Uta
Commentators have identified fear of liability as a major deterrent to the widespread land application of
sewage sludge. Liability issues regarding land application include not only legal liability, but also market
liability as a result of negative public perceptions of the land application of sewage sludge. Under current
law, municipal sewage treatment facilities, landowners, farmers, and even lenders are potentially liable for
risks arising from sewage sludge application, unless someone else assumes the risk through a clear and
legally enforceable mechanism. This article introduces this complex, evolving, and contentious
environmental issue. It investigates the various siting and toxic tort liability issues associated with the land
application of sewage sludge, and explores some of the risk-sharing mechanisms developed to minimize
the liabilities associated with the application of sewage sludge to farmland.
WATER ENVIRONMENT RESEARCH FOUNDATION, A TRADE ORGANIZATION OF THE SLUDGE PRODUCERS AND
SLUDGE SPREADERS -- REPORTS ON HARM TO COTTON AND OTHER CROPS FROM USE OF SEWAGE SLUDGE
AS FERTILIZER:
CALIFORNIA – KERN COUNTY
http://www.werf.org/pdf/03HHE1.pdf
Page "140 of 187" - "As a UC farm advisor in Kern County, CA responsible for irrigation and soil management, I have
worked with land appliers and farmers using biosolids for the last 10 years. My own field trials have shown widely
varying nitrogen mineralization from 10 - 71% one season. Other field observations include occasional crop
failures as well as some fields that have shown significant improvement and reclamation benefit from biosolids
applications.
Field level management, application rates and subsequent crop management are often less than precise. Other
farmers, water managers, and location regulators are concerned about leaching of toxicants and
pathogens and potential adverse publicity impacting crop value/sales, the list below suggests some production-
level tools and research that would help answer some of these questions."
PAGE "141 of 187" "4) Determination of plant toxicity mechanisms/correlation with form of biosolids: Researchers
have noticed occasional adverse crop damage across the US. Some of these incidents have been linked to excess
salinity and/or ammonium toxicity due to over application. Others, specifically cotton in Kern Country, have
suffered drastic stand losses or the loss of lower leaves and fruit later in the season with severe injury to
the upper leaves. Composite field soil and plant analysis indicated very acceptable levels for all salts/nutrients --
indicating the problem lies elsewhere. This problem has only been seen following the application of anaerobic
biosolids."
********************************************************************************************************
You might want to call to the attention of farmers in your area who are determined to spread sludge on their land
(and/or their tenant farmers who may be spreading sludge on their land_) possible adverse health effects to neighbors
and possible legal ramifications of making their neighbors sick:
SLUDGE FARMERS/LANDOWNERS SUED BY THEIR NEIGHBORS
...... a farmer in New Hampshire (Rosamond Hughes) was named as a defendant in the November 2000 Shayne
Conner sludge death lawsuit (which was ultimately resolved with the sludge spreader Synagro paying a substantial
cash settlement) . . .
...... Theodore R. Love, Jr. and Todd Love of Unicoi County, Tennessee, the owners of the sludged land, were named
as defendants in the recent $4.5 million lawsuit by sludge victim/worker Michael Seth Jones
...... Vernon Clyde Hollingsworth Jr., Michael Boran , James D. Brewer, Walter L. Brewer and Robert C. Brewer of
Desoto County, Florida, the owners of the sludged land, were named as defendants in the Dec. 2002 lawsuit filed by
17 sludge victims who allege sickness, trespass of pollutants and devalued homes.
..... PENNSYLVANIA Robesonia-area farmers Clarence D. and Esther Gelsinger, and Melvin C. and Gale Gelsinger
owners of the sludged land, were named as defendants in the February 2003 lawsuit filed by the parents of 17 year old
Danny Pennock who died of viral and bacterial pneumonia shortly after walking through a sludged field.
*************************************************************
GEORGIA - JUNE 2003 -
http://www.augustachronicle.com/stories/062403/lat_sludge.shtml
Jury: Augusta responsible for cattle deaths Web posted Tuesday, June 24, 2003
By Robert Pavey | Staff Writer
Jurors concluded today that the city of Augusta's sewage sludge was responsible for cattle deaths and
property damage at a Burke County dairy farm.
[NOTE: the "property damage" was the contamination of the farm's soil.]
“But the victory for Boyceland Dairy and members of the Boyce family was bittersweet: jurors awarded the
family only $550,000 - a mere fraction of the $12.5 million in damages sought by the plaintiffs.”
http://chronicle.augusta.com/stories/092007/met_144446.shtml
Settlement ends suit over sludge
Insurers will pay family, take care of legal fees
By Sandy Hodson| Staff Writer
Thursday, September 20, 2007
1 commentPRINTEMAIL
“Lloyds of London, National Union Insurance Co., Coregis Insurance Co. and St. Paul Insurance Co. agreed to pay $1.3
million for the cost of defending the city in the Boyce lawsuit.
The companies will pay the McElmurray family $1.5 million to settle their case.”
A settlement agreement approved by Augusta commissioners this week means the end of lengthy and costly litigation
over sewage sludge and dying dairy cows.
Former city attorney James W. Ellison said Wednesday that the settlement means insurance carriers will pay the city's
legal costs in defending a lawsuit filed by the Boyceland Dairy and pay R.A. McElmurray & Sons to settle its lawsuit
against the city.
"No costs to the taxpayers," Mr. Ellison said.
The McElmurray and Boyce families - dairy farmers in south Augusta and Burke County - initially sued the
city in 1998. They contend that sludge from the Messerly Wastewater Plant that the city offered as free
fertilizer contained dangerous amounts of heavy metals that poisoned their land and cattle, according to
reports in The Augusta Chronicle. The Boyce family lawsuit was filed in Richmond County Superior Court,
and a jury awarded the family $550,000 in 2003. The family had asked for $12.5 million.
******************************************************
MICHIGAN - HIGH NITRATE CARDBOARD SLUDGE CONTAMINATES NEIGHBOR'S WELL WITH NITRATES - INFANT
DIES FROM Methemoglobinemia ("Blue Baby" Syndrome)-- LAWSUIT FILED AGAINST THE OWNER OF THE SLUDGED
TREE FARM AS WELL AS THE CARDBOARD MILL WHICH WAS THE SOURCE OF THE SLUDGE -- CASE RESOLVED
BY OUT-OF-COURT SETTLEMENT
http://www.detnews.com/2003/metro/0308/13/b07d-243408.htm
Wednesday, August 13, 2003
Nitrates pollute water in 2 counties
EXCERPT:
""Because its origin typically lies in sewage disposal systems, runoff from barnyards, fertilized fields, and industrial
waste, nitrates also can indicate the presence of other contaminants. "
"In 1999, former Filer Township residents Stephen and Cindy McLintock discovered nitrate levels almost
three times above the DEQ's allowable level as they tried to sell their house.
Her family sued the cardboard mill and a tree farm across the street from their house for the premature
death of her baby, which they blamed on nitrates in the water from overapplication of the sludge.
The case was settled out of court last year, but it prompted further testing at former sludge dump sites."
************************************************************************************************************
MARYLAND: University of Maryland:
http://www.agnr.umd.edu/MCE/Publications/Publication.cfm?ID=226&cat=D
EXCERPTS
Sewage sludge is the waste product collected from municipal sewers. It is a mixture of human,
commercial and industrial wastes.
Safety is a major concern because sewage sludge may contain heavy metals such as copper, lead,
chromium and cadmium. If sewage sludge is applied to the soil in excessive amounts over a number of
years, unusable crops, injured or dead plants and heavy metal pollution of rainfall run off may result. In
addition, sewage sludge usually contains ample amounts of nitrogen and phosphorus, which if applied to
land at excessive rates can result in surface and ground water pollution and reduced crop yield. Finally,
sewage sludge can also contain measurable amounts of PCB's, other toxins and carcinogens.
Preapplication Considerations
- Sludge adds organic matter, which improves the physical properties of the soil.
2. Sludge may contain heavy metals that build up in the soil with continued sludge applications. High amounts of
these metals can be toxic to plants and have an uncertain impact on the food chain.
3. Sludge may contain organic chemicals, which, when used in excess, may be toxic to some crops and
can pollute the ground water.
4. Sludge adds plant nutrients.
5. Annual sludge applications are based on nitrogen as a limiting factor with metal accumulation limiting
the number of years of application.
6. The nitrogen and phosporus contents usually are very high, often resulting in high soil phosphorus
levels, and possibly nitrate pollution of ground water.
7. Because the potassium content in sludge usually is low, requiring a supplemental fertilizer may be
necessary.
8. Most crops can be grown on land which has received sludge. (However, note limitations).
9. The nutrients and heavy metals in sewage sludge may be variable. The analysis provided by the
contractor is at best an average of monthly samples and may not truly represent any one truckload
sent to your farm.
10. Years after sludge application low soil pH may allow more rapid toxic metal release to plants.
11. Some food processing companies refuse to purchase products grown on sludged land.
12. Sludge contractors obtain all permits, are responsible for all sludge analysis and apply sludge to your land at no
cost to you.
13. Odors emitted during sewage sludge application periods may cause complaints.
14. You must farm your land according to the provisions of the permit as long as the permit is in effect.
The permit allows all food crops to be grown with the condition that edible food parts cannot come into contact with the
sludge for at least 3 years after sewage sludge application. Tobacco cannot be grown on land that has received
sewage sludge. Pasture land cannot be grazed within one month of receiving sludge.
The permit requires specific soil pH conditions before and after the application of sewage sludge. The pH must be 6.5 or
higher at the time of the sludge application and must be maintained above 6.2 for the term of the permit. Some sewage
sludges contain high concentrations of lime (pH 10 or above) and should receive careful consideration before
application to land that is already at an optimum soil pH. A lower soil pH may allow excessive plant uptake of
heavy metals from the sewage sludge and movement of some metals within the soil.
The permit holder is required to post bond to ensure that the provisions of the permit are carried out. However, the
liability (of the sludge company) is limited to fulfilling the needs of the permit and is in effect only during
the term of the permit. Any additional or long-term liability for future physical or environmental damage on the
part of the landowner or sewage sludge user remains undefined.
"Make sure that your agreement makes the contractor fully responsible for physical damage to any land,
roadways, equipment, animals, humans or structures during sludge applications on your farm and outline a
procedure for damage assessment and compensation. "
- Do not allow application during wet soil conditions. Wet conditions promote soil compaction even with floatation
type tires.
- Do not allow loaded vehicles where they can become stuck. Do not allow unloading to the soil if a vehicle does
become stuck.
- Always observe what is going on and make your interests and presence known to the sludge contractor. Keep in
mind that the contractor is being paid by the sewage treatment plant to dispose of sludge and that your land is
the disposal site.
- Do not be afraid to complain to the contractor if you believe that something is wrong. Know who to call in the local
or state regulatory agency with a complaint. Contact your Extension agent for assistance. Make sure that the
truck weight tonnage delivered divided by the acres covered does not exceed the permitted rate.
- Make sure the sludge is uniformly applied. Do not be afraid to require a lesser application rate (the permitted
application rate is the maximum allowable).
- Request copies of all sludge analyses and review these with your Extension agent to ensure that you understand
what is being applied to your land.
- Keep records of how and what quality sludge was applied to each field so that in the long term you do not exceed
the limits of toxins or metals.
- Plan your fertilizer program so that you fully account for and supplement the sludge applications
- Maintain the soil pH at near neutral levels to retard metal release.
- Maintain soil records so that you and future users or owners of your land will understand the need
for soil pH control. (The degree of the liability of the landowner for future environmental or other
damage resulting from sludge application to his or her land has not been established.)
- Remember that the use of sewage sludge requires a long term commitment to proper soil
management.
March 22, 2005 8:04 PM
Subject: IATP - INSTITUTE FOR AGRICULTURE & TRADE POLICY - WHAT FARMERS SHOULD KNOW ABOUT
SEWAGE SLUDGE FERTILIZER
The Institute for Agriculture and Trade Policy promotes resilient family farms, rural communities and ecosystems around
the world through research and education, science and technology, and advocacy.
http://www.iatp.org/foodandhealth/issues_toxicsludge.cfm
Toxic Sludges and Fertilizers
Farmers use a variety of materials when growing food crops to promote plant growth and improve soil health. The
concept of "recycling" waste products for beneficial use is noble but not always appropriate because of the widespread
use of chemicals in today's society. For example, human waste has been used as a fertilizer for centuries. However, the
reality is that current regulations allow companies to dispose of liquid hazardous waste through the public sewer system.
Pollution levels in wastewater going through sewage treatment plant are compounded by widespread use of toxic
products in homes, schools, and businesses. Since the sewage system is meant to treat human waste, many chemicals
pass through to the sludge, where they can contaminate crops if the sludge is used as a fertilizer. Likewise with
industrial waste: using the wastes for their plant nutrient value could be beneficial but many waste materials–including
lime from pollution control equipment-contain significant amounts of dioxins, heavy metals and other toxic pollutants.
IATP advocates for proper disposal of toxic wastes, labeling of products grown with sludge or waste-derived fertilizers,
and full disclosure of sewage sludge or industrial waste contents to users. Absent these protections, IATP will continue
advocating for an end to use of sewage sludge or hazardous waste-derived fertilizer in food production.
1. Sewage sludge
2. Hazardous waste in fertilizers
3. Toxins in fertilizers used in the home and garden
Sewage sludge
Farmers who use conventional agricultural methods may use sewage sludge (sometimes referred to as "biosolids")
because sewage treatment plants give it away or sell it as a cheap fertilizer/soil amendment. They are generally
unaware that the sludge can contain toxic chemicals from industries, as well as hazardous materials from
residential use of toxic products, prescription drugs and personal care products that sewage treatment
plants have not been designed to handle. Thus, sewage sludge can be contaminated with radioactive
material and thousands of toxic chemicals (e.g. dioxins, plasticizers, flame retardants, mercury, cadmium,
lead) with potentially severe health effects. For instance, the sewage treatment plant that services
Minneapolis and St. Paul receives discharge from more than 600 industrial facilities. Bacteria, viruses and
other pathogens that can cause disease may also survive the sludge treatment process.
*****************************************************************
CANADA – INSURERS SAY SLUDGE SPREADING IS “ENVIRONMENTAL RISK”
http://www.safewatergroup.org/Stories/sludge_concerns_continue.htm#anchor1
Insurer Refuses to Assume Sludge Risk
Wellington Times, Aug. 25/04
Bay of Quinte Mutual Insurance Company is among a growing number of insurance companies that are
refusing to cover risks associated with spreading sludge on farm fields.
Jeff Howell, the branch’s general manager, said while they have no qualms with farmers spreading animal manure onto
fields, human feces is another story. “When they’re having something foreign brought into it, that’s totally
different.”
“It has to do with what our reinsurance will allow,” Howell explained. “It’s an environmental risk”
Howell did not offer his own take on the matter, saying: “I don’t personally have an opinion on whether it is or not. It very
well may be safe.” He added he recognizes it has to be disposed of somewhere, and that perhaps in time the company
will cover such property. “If it’s something our people need, we don’t ignore that.”
Insurers have concluded that the not enough is known and that the risk therefore is too great. “They’re
putting something foreign on a farm land that has potential to cause grief,” Howell said.
*****************************************************************
POLICY OF THE NATIONAL FARMERS UNION - ENACTED BY DELEGATES TO THE 101ST ANNIVERSARY
CONVENTION, ANAHEIM, CALIFORNIA - FEBRUARY 28 - MARCH 3, 2003
http://nfu.org/documents/policy/2003_nfu_policy.pdf
quote on page 64
National Farmers Union Opposes Class B sewage sludge
At its March 2003 Annual Convention the Delegates of the National Farmers Union enacted a 112-page Policy. On
page 64 the policy states:
The current practices of disposing hazardous wastes in existing landfills and surface mine sites, spreading hazardous
wastes and Class B biosolids on land surfaces, and injecting hazardous wastes in deep-well sites should be
discontinued. Alternative disposal sites should be identified which eliminate the risk of surface and groundwater
contamination, protect the health and safety of citizens, and protect the soil and water of agricultural lands, from which
the nation's food is produced.
CANADIAN FARMERS RESOLUTION - 2001 -
Here is the text of the resolution on sewage sludge that was passed at
the National Farmers Union National Convention November 2001:
Sewage Sludge WHEREAS tertiary sewage treatment generates large quantities of toxic "bio-solid" residues commonly
known as sludge, and
WHEREAS untreated sewage sludge is currently spread on farm fields in
various parts of the country,
THEREFORE BE IT RESOLVED that the NFU support the following principles
on sewage sludge:the spreading of untreated sewage sludge be prohibited;
the spreading of treated sewage sludge be prohibited until processes
are in place to remove heavy metals, pharmaceuticals, chemicals, and
numerous other toxic residues;- that until sludge spreading is prohibited, sludge contractors be required
to:give timely notice to neighbours within 2 km;
environmental impact studies be required by relevant authorities to
assess effects of each proposal application on the local environment.
CANADA – NOVA SCOTIA – OCTOBER 10, 2004
The Halifax Herald Limited Report slams biosolids on farm
Farm practices board says waste not handled in reasonable way
"We live in an agricultural area and we're proud of that. But we didn't consider
this an agricultural practice, we considered it an industrial waste site."
In its conclusions, the board recommended the agriculture minister establish a
working group, in consultation with the Federation of Agriculture, to develop a
code of practice for waste not generated by livestock.
CORNELL (UNIVERSITY) WASTE MANAGEMENT INSTITUTE, ITHACA, NEW YORK
Sludge Materials:
Considerations for Dairy Farms Regarding Use of Sewage Sludges, Sludge Products and Septage -
http://cwmi.css.cornell.edu/Sludge/dairysludge.pdf.
A 4-page summary of the report is also available –
http://cwmi.css.cornell.edu/Sludge/Dairysludgesummary.pdf
http://www.madisonmatters.com/Stories/Sludge/sludgeOpEd.html#KVDispatch_8_7_2002
VIRGINIA – DROUGHT AND SLUDGE/BIOSOLIDS = EXCESS NITRATES IN FODDER = CATTLE DEATHS
Hay fields, pastures and corn crops may contain excessive amounts of nitrates.
By J.B. Daniel, Extension Agent Virginia Tech
FROM: Kenbridge-Victoria Dispatch August 7, 2002 EXCERPTS:
"Many hay fields, pastures and corn crops may contain excessive amounts of nitrates due to drought conditions across
the state. Fields fertilized with biosolids or heavy applications of poultry litter are especially dangerous during
this extreme drought. Nitrate levels in excess of 0.44% nitrate ion or ppm. Nitrate N can be hazardous especially
to pregnant cows. High nitrate concentrations in feeds can result in abortion of calves. If nitrate levels are
high enough; death of cows or growing cattle can occur.
Deciding whether to test or feed a forage depends on the probability of high nitrate levels. The following forages
should be tested: Pastures and hay fertilized with biosolids; Pastures and hay fertilized with heavy applications of
poultry litter; Pastures and hay fertilized with more than 50 - 80 units of N; Droughty corn used for hay or silage; heavy
fertilized summer annuals; and any forage where there is doubt as to nitrate levels.
Biosolid fertilized fields are particular concern because this product is usually spread at the maximum
nitrogen rate. Under normal growing conditions biosolid fertilization will not cause nitrate toxicity to livestock pastures. .
Unfortunately, during dry years any type of heavy fertilization can cause high nitrate concentrations in hay and pastures.
FARMERS - COWS CATTLE - METALS
EXCERPTS FROM STATEMENTS MADE ON 2/7/2002 BY DR. RUFUS CHANEY: USDA PRO SLUDGE SPOKESMAN
TO ERIK APEDAILE, SUSAN LIVER, IRWIN OSINGA
SUBJECT: CANADIAN REVIEW OF HEALTH ASPECTS OF BIOSOLIDS LAND APPLICATION
"But when the fluid biosolids are spray applied on standing forages, the biosolids particles can get stuck to the
forages . . . when such contaminated forages are grazed, livestock can get high exposure to xenobiotics in
biosolids." (“xenobiotics “ = Studying the Metabolism and Disposition of Chemicals in Biological Systems -
Xenobiotics include such substances as TNT, PCBs, chlorophenols and PAHs.)
If dewatered biosolids or composts are land applied, the biosolids fall to the soil surface rather than get spread out on
leaves and stems of forages, and exposure is hardly different from the ingestion of surface soil model. If the biosolids
are incorporated into soil, uptake to forages is low, but soil ingestion does allow some livestock exposure and
absorption of xenobiotics. Grazing (not forage uptake) by animals could be getting these compounds into
food and milk, especially if the biosolids are surface applied."
Page A-2 IO: So a BMP (Best Management Practice) would be to not apply
biosolids to pastureland?
Dr. Chaney: 'The BMP IS TO INCORPORATE THE BIOSOLIDS IF THE FIELD WILL BE USED FOR PASTURE.
Biosolids can represent 12% of an animal's diet if fluid biosolids are surface applied . . . << 1% if incorporated
(animals consume about 1.5% soil on yearly average basis; and if the biosolids are mixed with soil, the surface soil to
which they have access contains greatly diluted biosolids."
Page A-4
EA: In Ontario soil pH needs to be 6.
R. Chaney: "Reg 503 doesn't have a pH limit, But the EPA reg assumes that if the soil pH falls below 5.5 that the
farmer needs to deal with Al and Mn (aluminum and manganese) toxicity in the soil by adding limestone . . . at 5.2 (pH)
you get yield reduction from Al toxicity . . . "
Page A-5
"I also suggested risk assessment for Co (cobalt) just to check that we don't have a rare high Co risk in
sludge in a particular area. Plants can take up enough Co to harm ruminant livestock under worst case
model conditions."
EA: What are the implications of this for Ottawa?
Dr. Chaney: "I THINK YOU SHOULD MAKE AN ISSUE OF VOLUNTARILY GIVING UP THE RIGHT TO SURFACE
APPLY LIQUID BIOSOLIDS. At least Ottawa needs to recommend incorporation, recommend tillage to incorporate the
biosolids before growing a crop, which would be grazed. Incorporation reduces potential exposure (worst case models)
remarkably. . . . If you give up pasture land it reduces flexibility. I RECOMMEND AS A GUIDANCE ALL BIOSOLIDS
BE INCORPORATED BEFORE GRAZING OCCURS. Standing crops with sprayed liquid can result in 25% sludge
in diet. INCORPORATION RESULTS IN LESS EXPOSURE FOR METALS, ORGANICs, PHARMACEUTICALS, AND
ODOUR. It is a BMP!"
RECOMMENDED METAL LEVELS IN SEWAGE SLUDGE:
"Although the higher limits of 503 can be tolerated by society, but if you can avoid putting these metals down the sewer
it's better. We have recommended "attainable" levels, e.g. Hg (mercury) 2-5 mg/kg vs. 20 mg/kg in Reg. 503 ---- 500
mg/kg Cu (copper) vs. 1600 ppm in 503, etc. The "attainable" levels are always better than the max allowed by
503."
Page A-6
"Fe (iron) in biosolids is typically about 20,000 mg/kg dry weight. Our work found biosolids causing harm to cattle when
fluid biosolids were surface applied on pastures, which contained about 120,000 mg Fe/kg (12%) .Ferrous
was solublized in the rumen. It induced copper deficiency in the cattle. . . . only spray applied fluid
biosolids was an issue. The 30-day waiting period would be important to minimise transfers from surface applied
biosolids."
"AGAIN, THE IDEA OF INCORPORATION IS IMPORTANT -- PARTICULARLY REGARDING THE IDEA OF
UNKNOWN ORGANICS -- INCORPORATION REDUCES THE TRANSFER TO LIVESTOCK VERY STRONGLY."
FROM DR. LYNN WILLETT, OHIO STATE UNIVERSITY:
"The federal and state EPA sewage sludge regulations are not consistent with the findings of the EPA
dioxin study. The US EPA regulations permit application of sewage sludge with dioxin levels significantly
above the mean rural background level of 3.6 ppt which was identified as having potential toxic and/or
carcinogenic effects. "
"If regulations change to meet the perceived risks stated in the dioxin study, soils receiving application of
sludge with dioxin levels above background are at risk of being permanently taken out of production in the
future."
http://www.oardc.ohio-state.edu/ocamm/willett.htm
Perceived risks of dioxins:
Are proposed EPA sewage sludge regulations protecting animal agriculture?
Dr. Lynn Willett
Ohio State University
The US EPA recently published 10-year study on dioxin which identifies 2,3,7,8-tetrachloro-p- dioxin, dioxin congeners
and other dioxin-like compounds as potent animal toxins as well as likely carcinogens. Although the carcinogenic
potential is controversial within the scientific community, the report states these effects may be “. . .occurring in humans
at general population background levels.”
According to the report, dioxins, by-products of combustion and industrial chemical processes, enter the food chain
primarily from volatilization from soil to forage crops to milk, dairy and beef products, which are identified as the source
of 60-90% of human exposure. Dioxins accumulate and are stored in fat tissues with clearance rates ranging from a
half-life of 58 days in lactating cattle to 7.1 years in humans.
“The federal and state EPA sewage sludge regulations are not consistent with the findings of the EPA dioxin study.
The US EPA regulations permit application of sewage sludge with dioxin levels significantly above
the mean rural background level of 3.6 ppt which was identified as having potential toxic and/or
carcinogenic effects. In addition, the study stated that “At elevated chronic exposures of about 10 times
background exposures, clearly adverse effects have been observed in both animals and humans.” The National
Sewage Sludge Survey indicates that about 90% of sewage sludge has dioxin levels between 3.6 and 300 ppt. Both
regulations require records of sewage sludge application be kept only 5 years even though the half-life in soil is 25 to
100 years. If regulations change to meet the perceived risks stated in the dioxin study, soils
receiving application of sludge with dioxin levels above background are at risk of being
permanently taken out of production in the future.”
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DAIRY COWS AND CATTLE EAT SOIL WHEN THEY GRAZE
It is estimated that grazing dairy cows and cattle may ingest up to one kilogram per
day of“soil”.
http://www.sustainable.wellington.net.nz/Editorial/Biosolids%20File,%20The.pdf
When sewage sludge is “top-dressed”, this means the animals are ingesting sludge. (we have pictures of
cows eating sludge on pastures where the sludge is surfaced applied and not incorporated.
PAGE 13 OF 23 http://cwmi.css.cornell.edu/Sludge/Dairysludge.pdf )
The following few entries deal with cows and cattle ingesting dioxins as they graze and consume
contaminated soil. While APHIS (USDA Animal and Plant Health Inspection Service) would like you to believe “air
deposition” is the largest source of dioxins in grazing animals, in fact land applied sewage sludge is ALSO
a significant source of dioxins in the milk and meat of grazing dairy cows and cattle.
Recent surveys by the US EPA and waste industry found that the average land applied
sewage sludge biosolids contains 50 parts per trillion of dioxins. To put this in perspective,
a 1991 EPA Risk Assessment under TSCA, and a Risk Assessment by ABT Associates of
Cambridge, Mass. in 1994 found that dioxin concentrations of UNDER 10 parts per trillion
in land applied paper mill sludge had adverse effects on development, growth and reproduction
of certain species of wildlife. (There is no difference in the harmful effects to wildlife and
livestock of dioxins in sewage sludge and the dioxins in paper mill sludge.)
http://www.amsa-cleanwater.org/advocacy/dioxin/dioxin.cfm )
Here the USDA confirms ingestion of dioxins by cows and cattle in contaminated vegetation and soil:
http://www.aphis.usda.gov/vs/ceah/cei/dioxins.htm#how_animals
How do food animals become contaminated with dioxin and related compounds?
“Deposition of airborne dioxins onto plant and soil surfaces, and subsequent ingestion of this
contaminated vegetation and soil by food animals, is considered the primary pathway by which dioxins
enter the food chain (Fries, 1995). The levels produced in this way are considered background levels. “
“Soil ingestion by livestock is also a significant source of exposure to dioxins (Fries, 1995b).
The use of pasture for ruminants is a factor in the soil pathway, since animals on pasture ingest
contaminated soil along with the vegetation.
The amount of soil ingested is related inversely to the availability of forage when pasture is the sole source of feed. Soil
ingestion is reduced when animals on pasture are given supplemental feed. Cattle confined to dirt lots also consume
small amounts of soil that can lead to meat residues. Travis and Hattemer-Frey (1991) predicted that ingestion of
contaminated soil should account for 29% and 20% of the total daily intake of dioxins in beef and dairy
cattle, respectively. “Since ingestion of dioxins in contaminated vegetation and soil is considered the
major pathway of exposure for food animals, different feeding practices such as confinement feeding,
grazing, and percentage grain fed should have significant effects on actual concentrations of dioxins in
animals.
While these factors have been theoretically researched and modeled (as described in the previous section), little
epidemiological or controlled research has been done to validate these hypotheses (Feil and Ellis, 1998).”
EPA ON BUILD UP OF DIOXIN CONCENTRATIONS IN THE SOIL FROM LAND APPLICATION OF SEWAGE SLUDGE:
Page 120 - 121 of 346: "Waste applications do not result in significant build up of the soil surface, nor does erosion
significantly degrade the soil surface . . . In other words, the modeled contaminant concentration in the till zone
could exceed the contaminant concentration in the waste. Indeed, this is physically possible for highly
immobile constituents if the waste matrix is organic and decomposes, leaving behind the constituents to
concentrate over multiple applications."
http://www.epa.gov/waterscience/biosolids/riskasappdx.pdf
by Memo dated April 21, 1994, Dr. Alan Rubin, US EPA, self described author of the Federal 40 CFR Part 503
sewage sludge rules declares:
“(For application of sludge to pastures, soil levels of
dioxins may not exceed one part per trillion.)”
[PRESS ADVISORY
TO: MEMBER ASSOCIATION LEADERS
FROM: ALAN B. RUBIN, SENIOR SCIENTIST (with his signature)
DT: April 21, 1994
RE: Dioxin in Biosolids
“Sludge with 50 parts per trillion dioxin concentration or above may not be land applied.
If the dioxin content falls between 10 and 50 parts per trillion, then dioxin levels in soils amended by
mill sludge must be tracked, and the total dioxin level in these soils may not exceed 10 parts per trillion.
(For application of sludge to pastures, soil levels of
dioxins may not exceed one part per trillion.)] “
(Needless to say these recommendations by Al Rubin were never memorialized in regulations . . .
http://www.penweb.org/issues/sludge/pcb-sludge.htm
PCBs from Sludge Effect Cattle
AUTHORS: Pocar, P;Perazzoli, F;Luciano, AM;Gandolfi, F
TITLE: In vitro reproductive toxicity of polychlorinated biphenyls: Effects on oocyte maturation and developmental
competence in cattle
SOURCE: MOLECULAR REPRODUCTION AND DEVELOPMENT, 58: (4) 411-416 APR 2001
ABSTRACT: Polychlorinated biphenyls (PCBs) are one of the most persistent and widespread groups of
endocrine disrupting compounds in the ecosystem. High concentrations of these substances are known to
be present in *sewage* *sludge* from industrial, agricultural, and domestic origin that is spread in
increasing amounts on arable land and pasture as fertilizer and is found in water, representing an
increasing risk for the reproductive health of farm animals.
Objective of this study was to determine the impact of PCBs on maturation and developmental competence of cattle
oocytes. Since PCBs are a family of 209 molecules present in the environment as a mixture, Aroclor-12 54, a pool of
more than 60 congeners, was used in these experiments as its composition is considered to be environmentally
relevant. Cumulus-oocytes complexes were exposed during IVM to serial concentrations of Aroclor-1254 (between 1
mug/ml and 0.0001 mug/ml) and compared with control groups. Aroclor decreased the percentage of oocytes that
reached metaphase ii stage after 24 hr, at doses as law as 0.01 mug/ml. Groups treated with 0.001 mug/ml or above,
showed an impaired fertilization rate and a dramatic increase of polyspermy. Moreover, exposure during maturation
resulted in a reduced proportion of oocytes that cleaved and developed until blastocyst stage although no differences
in embryo cell numbers were observed.
The present study indicates that very low PCBs concentrations are sufficient to disrupt bovine oocyte
maturation, its fertilization, and developmental competence. These results also provide a set of reference
data for the assessment of the risk posed by these substances to animal reproductive health, though
further work will be necessary to equate in vitro doses to in vive exposures. (C) 2001 Wiley-Liss, Inc
.
DOCUMENT TYPE: Article
LANGUAGE: *English*
IDS No.: 406AZ
ISSN: 1040-452X
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http://cwmi.css.cornell.edu/Sludge/AAAS/Medvitz.html
Sludge, Sludge on the Range: Unresolved Science in the 503 Regulations.
(A paper presented at the AAAS Annual Meeting in Philadelphia, February 14, 1998 and at the 1998 California Plant
and Soil Conference: Agricultural Challenges in an Urbanizing State, January 21-22, 1998. California Chapter of
American Society of Agronomy and California Fertilizer Association.)
by Albert G. Medvitz P.O. Box 565 Rio Vista, CA 94571 email: amedvitz@wco.com
"Organic Pollutants
The seriousness of the gaps in the research about the longer term effects of sludge borne pollutants on livestock is
made more apparent by the lack of research on the impacts of organic pollutants. The EPA conducted initial screening
of pollutants using a national survey of POTWs, the so called National Sewage Sludge Survey. Before conducting the
survey, the rulemakers a priori eliminated significant organic pollutants on the basis that their use has been banned in
the United States. As the National Research Council notes in its report on sludge, the exclusion was an error
and the survey was flawed (20). Possible exposures are underestimated."
"Again, organic pollutants, when they were considered, were considered individually and not in synergy
with other organic or inorganic pollutants."
"The absence of research on the effects of both the organic and inorganic chemical species on long term breeding
health of animal herds and flocks leaves open serious questions for producers about the protectiveness of the 503
regulations. Anyone close to the sheep and cattle production systems of this country knows that they have been
operating under difficult economic circumstances for close to a decade. Further, they understand that lowered
conception rates of a percentage point or two, increased abortion rates, earlier deaths of animals, or even
modest shortening of breeding span could have a substantial economic and management impacts on
livestock enterprises. They also know that such effects resulting from sludge applications would be hard to
identify and trace."
April 2004
TO THE EDITOR:
This is in response to the excellent article by Kath Gourley and Jeremy Watson.
Scottish farmers and meat and dairy producers are correct to oppose spreading
sewage sludge on dairy pastures and livestock fields because it contains a great deal of toxic
industrial wastes.
Cornell University Waste Management Institute, Ithaca, New York, on US EPA’s dioxin risk assessment:
“Grazing cattle ingest from 1-18% of their dry matter intake as soils . . .
when sludge is spread on pasture or growing crops, a significant amount ends up adhering to the leaves of plants.
This residue is not easily removed by rainfall. Thus it is likely to be an important route of exposure to pastured
animals and also to animals eating harvested forage (Wilson et al., 1997)."
K. Rideout and K. Teschke, National Instututes of Health, USA - Potential for increased human food borne
exposure to (dioxins and furans): “Studies of soil after sludge application, concentrations of dioxins and
furans ranged from 1.4 to 15 pg TEQ/g.
" . . . all studies that measured soil PCDD/F concentrations before
and after sludge application found increased contamination after sludge amendment.
Dioxin and furan concentrations increased by factors of 1.4 – 17.0 (mean 7.1) after sludge
application, indicating that application of sewage sludge increases PCDD/F
contamination in soil.” " . . . the use of sludge on land used to graze animals appears likely to result in increased
human PCDD/F exposure.”
U. S. Dept. of Agriculture: "Uptake by vegetation is the main route by which atmospheric organic pollutants get into
the food chain. Pastureland used by grazing farm animals is of particular concern from a human health perspective,
because the bulk of human exposure to dioxins comes from consumption of meat and dairy products."
"Grazing . . .by animals could be getting these compounds into food and milk, especially if the biosolids are surface
applied."
Dr. J. Michael Wilkinson of UK, June, 2003: "Recycling of sewage sludge to grassland . . .
there is still a danger that grazing animals may ingest elevated concentrations of PTM
(potentially toxic metals). Biosolids may adhere to herbage after the surface application of sewage sludge to
grassland. The repeated surface application of sewage sludge to
grassland can lead to elevated concentrations of PTM at the soil surface. . . "
from New Zealand : "However, the need for a formal framework to control spreading of human waste has been
highlighted by the disclosure of "beef measles" in a Dannevirke cattle herd.
The parasite, Taenia saginata, can cause tapeworms up to 25m long in humans. According to a draft of the proposed
rules for use of "biosolids" on farmland, the parasite has been a problem overseas "where cattle have been grazed on
pasture irrigated with untreated human sewage sludge".
In August, 2003, the City of Augusta, Georgia, (USA) was ordered by a jury to pay $550,000 to a local dairy farm
for the death of their cows and the contamination of their land by toxic sewage sludge.
The City of Sparta, Missouri, (USA) was ordered to pay a settlement to a local dairy farmer because of runoff from his
neighbor's sludged property which killed his cows. Quoting from the Court's decision: "The sludge contained
"substances and compounds, toxic to humans and animals, i.e., fluoride, cadmium, lead, mercury, iron,
arsenic, aluminum, selenium and molybdenum." Said substances and compounds migrated from Bradens'
land to Rollers' farm, causing damage including diminished milk production, death of cows and loss of
breeding opportunity. "
Respectfully submitted, Helane Shields, sludge researcher, PO Box 1133, Alton, NH, USA 603-875-3842
**************************************************
HALIFAX, NOVA SCOTIA – NOVEMBER 2004:
The Nova Scotia Federation of Agriculture is now discouraging farmers from
using sewage sludge as fertilizer. (from Maureen O’Reilly, Ontario, Canada)
Sent: Tuesday, November 09, 2004 11:06 AM
Subject: RADIOACTIVE SLUDGE - ILLINOIS - RADIUM IN DRINKING WATER - RADIONUCLIDES
RECONCENTRATED IN BOTH CLASS A AND CLASS B SEWAGE SLUDGE BIOSOLIDS
"In an August draft report intended to give local officials advice about radium treatment and disposal
methods, the U.S. Environmental Protection Agency concluded that spreading radium-contaminated sludge
on corn and soybean fields could create radium hot spots that would require future cleanup."
http://www.chicagotribune.com/news/local/chi-0411090232nov09,1,6836178.story?coll=chi-news-hed
Radium filtering doesn't get rid of it
It's taken out of water but put on land, in rivers
By Michael Hawthorne Tribune staff reporter Published November 9, 2004
Dozens of northeastern Illinois communities are stripping their drinking water of cancer-causing radium, only to dump
the radioactive element back into the environment in sludge spread on farm fields and wastewater pumped
into rivers and streams.
******************************************************
Sent: Saturday, April 17, 2004 7:26 PM
Subject: WERF SUMMIT - CALIFORNIA KERN COUNTY CROP DAMAGE - PROBLEMS COTTON ANAEROBIC
SLUDGE BIOSOLIDS
http://www.werf.org/pdf/03HHE1.pdf
Page "140 of 187" - "As a UC farm advisor in Kern County, CA responsible for irrigation and soil management, I have
worked with land appliers and farmers using biosolids for the last 10 years. My own field trials have shown widely
varying nitrogen mineralization from 10 - 71% one season. Other field observations include occasional crop
failures as well as some fields that have shown significant improvement and reclamation benefit from biosolids
applications.
Field level management, application rates and subsequent crop management are often less than precise. Other
farmers, water managers, and location regulators are concerned about leaching of toxicants and pathogens and
potential adverse publicity impacting crop value/sales, the list below suggests some production-level tools and
research that would help answer some of these questions."
PAGE "141 of 187" "4) Determination of plant toxicity mechanisms/correlation with form of biosolids:
Researchers have noticed occasional adverse crop damage across the US. Some of these incidents have been
linked to excess salinity and/or ammonium toxicity due to over application. Others, specifically cotton in Kern
Country, have suffered drastic stand losses or the loss of lower leaves and fruit later in the season with severe
injury to the upper leaves. Composite field soil and plant analysis indicated very acceptable levels for all
salts/nutrients -- indicating the problem lies elsewhere. This problem has only been seen following the application of
anaerobic biosolids."
http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=9491570&dopt=Abstract
1: J Environ Sci Health B. 1998 Jan;33(1):99-121. Related Articles, Links
The uptake of radionuclides by beans, squash, and corn growing in contaminated
alluvial soils at Los Alamos National Laboratory.
Fresquez PR, Armstrong DR, Mullen MA, Naranjo L Jr.
Environment, Safety and Health Division, Los Alamos National Laboratory, NM 87545, USA.
Pinto beans (Phaselous vulgaris), sweet corn (Zea mays), and zucchini squash (Cucurbita pepo) were
grown in a field pot study using alluvial floodplain soils contaminated with various radionuclides within Los
Alamos Canyon (LAC) at Los Alamos National Laboratory, New Mexico. Soils as well as washed edible (fruit) and
nonedible (stems and leaves) crop tissues were analyzed for tritium (3H), cesium (137Cs), strontium (90Sr),
plutonium (238Pu and 239,240Pu), americium (241Am), and total uranium (totU). Most radionuclides, with the
exception of 3H and totU, in soil and crop tissues from LAC were detected in significantly higher concentrations (p <
0.05) than in soil or crop tissues collected from regional background locations. Significant differences in radionuclide
concentrations among crop species (squash were generally higher than beans or corn) and plant parts (nonedible
tissue were generally higher than edible tissue) were observed. Most soil-to-plant concentration ratios for radionuclides
in edible and nonedible crop tissues grown in soils from LAC were within default values in the literature commonly used
in dose and risk assessment models. Overall, the maximum net positive committed effective dose equivalent (CEDE)--
the CEDE plus two sigma for each radioisotope minus background and then all positive doses summed--to a
hypothetical 50-year resident that ingested 352 lb ([160 kg]; the maxiumum ingestion rate per person per year) of
beans, corn, and squash in equal proportions was 74 mrem y-1 (740 microS y-1). This upper bound dose was below the
International Commission on Radiological Protection permissible dose limit of 100 mrem y-1 (1000 microS y-1) from all
pathways and corresponds to a risk of an excess cancer fatality of 3.7 x 10(-5) (37 in a million), which is also below the
U.S. Environmental Protection Agency's guideline of 10(-4).
PMID: 9491570 [PubMed - indexed for MEDLINE]
************************************************************************
SLUDGE FARMERS AND WEEDS:
recent comments from Virginia and elsewhere:
"Has anyone researched the cumulative affect of applying herbicides on top of sludge?"
**********************************************************************
"we have been told many times that application of sewage sludge results in horrendous weed problems . . .
. "
*****************************************************************************************************
"I have observed the same circumstances in my community...weeds, weeds and toxic weeds."
******************************************************************************************************
RECENT EMAIL MESSAGE FROM VIRGINIA: - "As I told Mr. ___________this week; spraying for weeds occurred on the
farm adjoining mine. This spraying lasted one day and was applied to the pastures and hay fields where the sludge was
applied 4 years ago. The weeds are taking over the entire farm!!! How effective the spreading will be is a big
question. I personally spoke with the Southern States employee who was doing the spreading because I was concerned
for the health and safety of my Arabians horses; just yards away. He assured me the liquid was safe and would kill
"most of the weeds". It is amazing to look at these fields and see the huge, numerous weeds."
****************************************************************************************
Farmers are told they are getting “free” fertilizer, but many must buy potassium since this ingredient is
missing from sludge. Also, many farms are plagued with horrendous weed problems after sludge
application, resulting in added expense for herbicides. And researchers in Israel have documented
increased leaching of pesticides from sludge amended soil.
**********************************************************************
"This is a KEY question that has not been answered. One tenant farmer growing corn in NH once said at a public
meeting that he uses ten different kinds of herbicides during the growing season on his sludged land.
Dr. David Lewis has authored or co-authored a number of papers about how certain pesticides, when used on sludged
crops, will behave differently than how they behave in crop/soil research that needed to be done to have the EPA
approve them for agricultural use. Heavy metals, for example, can either slow down degradation of pesticides ( the
general term for all such chemicals, incl. herbicides) or cause them to break down too quickly. In the first instance, they
would pose an additional risk to wildlife, soil organisms, and public health, in the second instance they would not work
the way they were designed to work, so the farmer would be tempted to user higher application rates and not follow the
label ( thus breaking the break the law) in order to get results.
At any rate, most of the research on farm chemicals has always been done on unsludged land. Maybe some studies
are being done on this at Cornell.
Your question opens an additional question -- of the many other unknowns of using sludge as a fertilizer, and was, I
believe, not covered in the NRC report."
**********************************************************