From: Helane Shields
To: Stevens.Rick@epamail.epa.gov ; SAM HADEED, WEF ; DR. JIM SMITH, EPA, CINCINNATI
Sent: Wednesday, June 18, 2008 7:40 PM
Subject: to US EPA and WEF - human and animal prions in Class A sewage sludge biosolids compost which
is promoted for home use as pathogen free
To Dr. Jim Smith, US EPA
To Rick Stevens, US EPA sludge biosolids administrator
Sam Hadeed, WEF
The EPA and waste industry are promoting Class A sewage sludge "biosolids" compost as being "virtually pathogen
free" and or "sterile".
Prions are pathogens. Research indicates prions are present in human feces, blood and urine, all of which enter
public sewers.. The Wisconsin DNR, EPA, etc. has found that the wastewater treatment process reconcentrates the
prions in sewage sludge biosolids. No sludge pathogen reduction method currently in use inactivates infectious prions.
Land applying sludge biosolids containing infectious human and animal prions poses a risk to humans. EPA and
waste industry encourage spreading Class A sludge biosolids compost on lawns, flower gardens and home vegetable
gardens. This poses an exposure risk to children, who eat dirt with their hand to mouth behavior. Others may be
exposed to pathogens by family pets who walk and roll in the sludge biosolids and track dirt/sludge into the home.
Cows and livestock, deer, elk, moose, etc. may be ingesting infectious human and animal prions with the sludge and
dirt they consume when they graze on hay fields, grazing lands and dairy pastures which have been topdressed with
sludge. As more and more different animals become infected with transmissible spongiform encephalopathies, the
myth of the "species barrier" falls.
Research by Joel Pedersen, et al, funded by US EPA, has shed a great deal of light on the risks of land applying prion
infected sludge biosolids:
"Soil may serve as an environmental reservoir for prion infectivity and contribute to the horizontal transmission of prion
diseases (transmissible spongiform encephalopathies [TSEs]) of sheep, deer, and elk. TSE infectivity can persist in
soil for years, and we previously demonstrated that the disease-associated form of the prion protein
binds to soil particles and prions adsorbed to the common soil mineral montmorillonite. . . "
Even more disturbing was the finding that soil can amplify infectious prions by a factor of 680: "Cox
proportional hazards modeling revealed that across the doses of TSE agent tested, Mte increased the effective
infectious titer by a factor of 680 relative to unbound agent. "
[Soil amplification of infectivity by a factor of almost 700 is particularly significant when you consider how small an
infective dose is:
USDA/APHIS "The significance of small amounts of infectivity become evident when you consider that
experimentally it has been shown that exposure of sensitive species to as little as 1.0, 0.1 or even 0.01
grams of infected nervous tissue can induce infection. "
"Given all of the above (except complete burning in closed furnaces), it must be recognized that no process has been
demonstrated to be 100 % effective in removing TSE infectivity and there will be some residual levels of infectivity
remaining after treatment."
www.aphis.usda.gov/NCIE/oie/rtf_files/tahc-carcass-disp-jan05.rtf "]
Pederesen (continued) "We and others have hypothesized that soil may serve as a reservoir of TSE infectivity
[8,9,22,23]. Deliberate and incidental ingestion of soil by ruminants can amount to hundreds of grams daily [24,25].
Prions enter soil environments via decomposition of infected carcasses [8,26], alimentary shedding [11,27,28],
deliberate burial of diseased carcasses/material [29], and possibly, urinary excretion [30].
"Our results argue for excluding inputs of prions to municipal wastewater
treatment facilities that would result in unacceptable risk of prion disease
transmission via contaminated biosolids."
"Our results demonstrate that adsorption of TSE agent to inorganic microparticles and
certain soils alter transmission efficiency via the oral route of exposure." (Pedersen, et al- 2007 )
One of the primary sources of infectious prions in sewage sludge biosolids is the one being studiously ignored by the
EPA and waste industry - namely, the 2 -25% of 5.2 million Alzheimer's Disease victims who are actually infected with
sporadic Creutzfeldt Jakob Disease according to peer reviewed, published research:
"- Thousands of human victims of sporadic Creutzfeldt Jakob Disease (sCJD) are also shedding
infectious prions into public sewers, to end up in both Class B sewage sludge and Class A sludge
biosolids compost. Between 2 and 25% of the 4.5 million cases of Alzheimer’s Disease and senile
dementia victims in the US are actually infected with sporadic CJD. (Manuelidis, et al, 1989; Bendixen,
1996; Boller, et al, 1989, 1995; Harrison, 1991; Teixeira, 1995; Warren, et al, 2005). "
Recent research confirms that feces can contain infectious prions:
"The Journal of Infectious Diseases 2008;198:81–89 © 2008 by the Infectious
Diseases Society of America. All rights reserved.
0022-1899/2008/19801-0015$15.00 DOI: 10.1086/588193
MAJOR ARTICLE
Transmission and Detection of Prions in Feces
Jiri G. Safar,1,2 Pierre Lessard,1 Gültekin Tamgüney,1,2 Yevgeniy Freyman,1 Camille Deering,1 Frederic Letessier,1
Stephen J. DeArmond,1,3 and Stanley
B. Prusiner1,2,4
Incubation times of 140 days and a rate of prion infection of 80%-100% among exposed animals
suggested transmission by feces, probably via coprophagy.
Our findings suggest that horizontal transmission of disease among herbivores may occur
through the consumption of feces or foodstuff tainted with prions from feces of CWD-infected
cervids and scrapie-infected sheep."
(see file attached on prions in intestines, excreta, feces, etc.)
"Prions can cross the intestinal barrier by riding piggyback on ferritin, a protein normally absorbed by the
intestine. Because ferritin shares considerable homology across species, these data suggest that PrPSc-
associated proteins, in particular ferritin, may facilitate PrPSc uptake in the intestine from distant
species, leading to a carrier state in humans. (Singh, et al 2004)"
“ . . . enteric infection at early as well as later stages of (CJD) disease, and regardless of the route of
agent entry, implicates potential environmental spread by fecal matter.” (Radebold, et al 2001)
The US EPA and waste industry are perpetrating a dangerous fraud on the American public by continuing
to deny the presence of infectious human and animal prions in sewage sludge "biosolids".
You have been warned of the risks by EPA funded researchers. There is no sewage treatment process
that inactivates prions. And there is no way to prevent the shedding of human prions/pathogens into
public sewers from the tens of thousands of victims of sCJD. The sewage treatment process
reconcentrates the prions in the land applied sludge. Soil amplifies the infectious prions by a factor of
680. The USDA/APHIS says as little as 0.01 gram can initiate infection.
Your claims that Class A sludge biosolids compost is "virtually pathogen free" and/or "sterile" are false.
You have an legal and moral obligation to cease your untrue promotions and to warn the American public
of the risks from the pathogenic content of this waste product.
Helane Shields, PO Box 1133, Alton, NH 03809 hshields@worldpath.net http://www.sludgevictims.com http://www.
sludgevictims.net