EPA Sludge Cover Up and Denial of Human Health Risks

The attached testimony by Dr. Caroline Snyder is worth reading and posting. The EPA also knew in 1982 that sewage treatment plants generated antibiotic resistant bacteria (see below). The author is an EPA scientist, the paper was peer reviewed, and after the EPA started promoting land applications of sewage sludge---the study was suppressed and no longer available at the EPA, DHHS or the CDC.

We found this paper on microfiche at one of the EPA libraries scheduled for closure in 2007. Drs. McGowan and Snyder have attempted to get the EPA, CDC, USDA, DHHS, and FDA to respond to "what they knew--and when they knew it" prior to the EPA regulations 40 CFR Part 503 effective January 1993.

The 1982 EPA study by Meckes notes that sewer plants and their byproducts spread pathogens and antibiotic resistance into the environment at large, see: 1982 EPA paper http://aem.asm.org/cgi/reprint/43/2/371.pdf .

Also see the email from Dr. McGowan below to all federal agencies about sewage treatment plants generating antibiotic resistant bacteria and sludge spreading that further moves the pathogens via the air into human lungs. Dr. McGowan is a retired physician and hydro-geologist with 40 years experience with the World Health Organization. He is one of our strongest advocates and a ready source of information to assist us with local problems.

From: edo_mcgowan@hotmail.com
To: hbuxton@usgs.gov; faison.brendlyn@epamail.epa.gov; apruden@engr.colostate.edu; bastian.robert@epamail.epa.gov; chaneyr@ba.ars.usda.gov; jennings.susan@epamail.epa.gov; smith.james@epamail.epa.gov; stevens.rick@epamail.epa.gov; suzanne.fitzpatrick@fda.hhs.gov; swietlik.william@epamail.epa.gov; tmcmahon_at_engr.wisc.edu@epamail.epa.gov; skhaack@usgs.gov; aoh8@cdc.gov; thomas.dana@epamail.epa.gov; jackson.lisa@epa.gov; commissioner@fda.hhs.gov; kathleen.sebelius@hhs.gov; edo_mcgowan@hotmail.com
Subject: RE: Source Tracking Aerosols Release. This is a formal request for answers, see below.
Date: Sat, 5 Dec 2009 06:21:02 +0000

I have communicated with both CDC and EPA on the subject of antibiotic resistance in sewage sludge. The answers back have generally been that little activity exists in this area by the former agency and for the latter, the subject seems to be off limits for discussion. The question that comes to mind is why this may be the case? CDC considers the spread of antibiotic resistance to be a high priority subject. We know that illness associated with antibiotic resistance are now killing more Americans than AIDS. If we also fold into this the work by Mark Meckes done back in the early 1980s, the question becomes a very compelling and the answer thus profound, see: http://aem.asm.org/cgi/reprint/43/2/371.pdf.

The case for an answer becomes yet more interesting when we look at the work in 2007, via the American Society for Microbiology. We find that Baertsch et al's paper "Source Tracking Aerosols Released from Land-Applied Class B Biosolids during High-Wind Events" discusses off site movement. The interesting thing here is the distance traveled by critical aerosols. How far can these aerosols move and cause damage? I worked with the Ag Engineering staff at UC Davis when we tracked Propanil for 50 miles to confirm tissue damage in distant orchards. Veterinarians in the UK have noted foot and mouth in isolated herds that were several miles distant from any source. Considering the ability for the gut flora to take in merely a single bit of genetic information, by the next day the numbers are very impressive. Is it wise to continue ignoring this issue?

Thus, I wrote Jordan Peccia, the corresponding author as noted below. Consequently, the same question could also be put to each of the following agencies---as a formal requested series of questions---to CDC, FDA, H&HS, USDA, and of course yet again to EPA. A previous request was sent to these agencies but no usable answers were forthcoming----in fact most did not answer-----again why? The salient point of the Baertsch et al paper is that off-site movement of aerololized sewage sludge. This then also means that antibiotic resistant genes (ARGs) are capable of aerosol movement to off-site targets. Since these are very small but very robust fragments their settling rate is almost nill.

Jaydeep Ghosh, of Bowling Green State University, Geology, in 2005 looked at aerosol generation from land applied sewage sludge. He noted that "compared to the data collected on the day of application, total bacteria, Staphylococcus aureus, and gram-negative bacteria were elevated 2 days after biosolids application. Levels decreased to control level 13 days after application, except for Staphylococcus aureus, which was highest 13 days after application. It can be concluded that pathogenically nontreated class B biosolids are capable of generating potential pathogens in the air. This increased content might be responsible for reported health problems in nearby residents during the post-application period", see: http://etd.ohiolink.edu/view.cgi?acc_num=bgsu1131322484

Anyone who lives or works in an agricultural area knows that tillage and wind cause large movements of soil and dust that are equal to that found for water erosion. The largest source of aerosol generation is not the application of sewage sludge but its tillage. Thus if one looks at Baertsch et al's paper which noted wind speeds of 11 mph and adds in the effect of tillage, one can see that there may be large volumes moving down wind. How far are the nearest critical targets from the proposed biosolids application area or from the area receiving disking? In the Caribbean, dust arising from Africa causes respiratory disease. That is a transit of somewhere over 3,000 miles and during the 2 to 3 weeks the dust is in transit, it is subjected to intense UV at the very high altitudes it attains while crossing the Atlantic. How do these types of studies on areosols correlate to setback distances suggested for the application of sewage sludge?

From Tellier's tables, I generated a small series of curves, the base data for which are noted (R Tellier - Emerg Infect Dis, 2006 Nov;12(11):1657-62. ncbi.nlm.nih.gov)

These curves (not shown here) are for the drift of particulates in the following range: 10uM and 5uM. Something smaller than 3uM will essentially not settle out and this is also the range in which pathogens and genetic fragments fall and also those that reach the deepest recesses of the respiratory system.

The formal questions, then---------1) what governmental agency has been working along these lines, i.e., antibiotic resistance in sewage byproducts, 2) If none, then assuming that antibiotic resistance is a national health care issue, when are the citizens to expect some serious inquiry into the subject, and following that, 3) why has EPA apparently done little to nothing with the Meckes study? 4) Are other agencies thus to step in and pick up the issue? 5) If so, where is the underlying policy and budgetary directives to these sister agencies to take up the slack? 6) A question for EPA, what was the formal routing for the Meckes paper to allow it to be published, i.e., what are the formal hurdles and policy procedures for publication of such a paper-------who must pass judgement on the paper before it is allowed to be published?

Based on wastewater industry dogma and its controlling standards, sewage sludge is a benign soil amendment for farmland. If, however, one reviews the current medical and scientific literature, a different picture emerges, one that raises serious questions about the benevolence of these activities and the efficacy of the underlying standards. Thus, the issue takes on aspects of a political and not a scientific argument. Many regulatory agencies refer back to EPA but do not receive a factual response. The issue is passed on to ill-prepared state and local authorities (Office of Inspector General, Status Report, Land Application of Biosolids 2002-000004, March 28, 2002; www.epa.gov/oig/reports/2002/BIOSOLIDS_FINAL_REPORT.pdf.). The March 2002 OIG Status Report on Land Application of Biosolids made it very clear the Compliance and Enforcement Division was not capable of enforcing any laws to protecting water or public health. The OIG said, "Compliance and Enforce has disinvested from the program." Not only that but, "EPA officials said investigating health impacts from biosolids is not an EPA responsibility; rather, they believe it is the responsibility of the National Institute of Occupational Safety and Health, the Centers for Disease Control, and local health departments." Thus, if this is the case, where is the underlying policy and budgetary directives to these sister agencies to take up the slack? In discussions with CDC, I was informed that there was no particular focus on these issues. Who then watches the chickens, the fox?

Dr Edo McGowan


Jordan, this is interesting and aerosols may well act as a mechanism to spread antibiotic resistance to down-wind, off site targets. Please pull up the EPA study completed and reported in 1982 which also discusses antibiotic resistant bacteria in sewage sludge (Mark Meckes' published in 1982 ;). Also, note the paper by the Canadian authors who looked at Sugar Creek (http://www.ingentaconnect.com/content/nrc/cjm/2004/00000050/00000008/art...). Thus, there may be large off-site movement of antibiotic resistant genes and pathogens by both air and water. Could you: 1) let me know that you received this email, and 2) give me your thoughts on this. A more complex situation may be regional dust storms.

How does information in your paper along with the carriage of antibiotic resistance affect dust and dust storms? I'm working in this area related to the aerial movement of soil containing sewage sludge (biosolids). It is estimated that 60% of the total U.S. generated sewage sludge (biosolids) becomes land applied. It is estimated that three tons of sewage sludge is generated for each million gallons of sewage entering a treatment plant. Land application of sewage sludge has been going on for some years and thus there is a build-up within the soil profile of pathogens, heavy metals and contaminants of emerging concern. From---Cornell Waste Management Institute----Case for Caution Revisited:. Once contaminated, stopping the application of pollutants such as metals and many organic chemicals that are in sewage biosolids will not correct the problem. The contamination will remain for decades or centuries.

It is also important to consider the synergistic effect on the barrier protection of fragile respiratory tissues by mechanical or chemical irritants and the entry of pathogens and thus antibiotic resistant genetic information through disrupted barriers.

The climate scientists are estimating a return to dust bowl days on a permanent basis. With thousands of acres of farmland in the drought-prone areas and with multiple-year sludge application and a dust storm, very large, regional areas may be impacted lifting tons of sluged soils, their contained pathogens and toxins into the air. Unfortunately, US EPA , although promoting the land application of sewage sludge has no comprehensive data base on where and how much sewage sludge has been applied. Thus it may be difficult to do strategic planning. As the droughts hit and the water availability is reduced. The costs of bringing ground water to the surface in numerous areas may no longer be economically supportable and crops will be abandoned. I saw this through out Africa and it will happen here. Also farmers will, in anticipation of converting ag land to urban, spend down their soils so those soils may have an increased tendency to blow. As to pathogens, for the long-lived spore formers, as well as dried yet viable DNA containing virulence and antibiotic resistance data, this combination of pathogen and chemical-mechanical irritation of the respiratory tract may overwhelm the capacity of health care centers to deal with the incoming ill. Because of the levels of antibiotic resistant pathogens within sludge and the transfer of that information to the soil bacteria, inhalation of dust may see many of these respiratory infections that will be difficult to treat. Where, (a rhetorical question) with the above in mind, is the discussion and preparedness?

Thanks for doing the paper,


Increased frequency of drug-resistant bacteria and fecal coliforms in an Indiana Creek adjacent to farmland amended with treated sludge
Authors: Shivi Selvaratnam; J D. Kunberger
Source: Canadian Journal of Microbiology, Volume 50, Number 8, 1 August 2004 , pp. 653-656(4)

Many studies indicate the presence of human pathogens and drug-resistant bacteria in treated sewage sludge. Since one of the main methods of treated sewage disposal is by application to agricultural land, the presence of these organisms is of concern to human health. The goal of this study was to determine whether the frequency of drug-resistant and indicator bacteria in Sugar Creek, which is used for recreational purposes, was influenced by proximity to a farmland routinely amended with treated sludge (site E). Surface water from 3 sites along Sugar Creek (site E, 1 upstream site (site C) and 1 downstream site (site K)) were tested for the presence of ampicillin-resistant (AmpR) bacteria, fecal and total coliforms over a period of 40 d. Site E consistently had higher frequencies of AmpR bacteria and fecal coliforms compared with the other 2 sites. All of the tested AmpR isolates were resistant to at least 1 other antibiotic. However, no isolate was resistant to more than 4 classes of antimicrobials. These results suggest that surface runoff from the farmland is strongly correlated with higher incidence of AmpR and fecal coliforms at site E.Key words: drug-resistant bacteria, indicator bacteria, treated sludge, surface runoff.


Appl Environ Microbiol. 2007 July; 73(14): 4522-4531.
Published online 2007 May 18. doi: 10.1128/AEM.02387-06. PMCID: PMC1932808

Copyright © 2007, American Society for Microbiology
Source Tracking Aerosols Released from Land-Applied Class B Biosolids during High-Wind Events
Carolina Baertsch,1 Tania Paez-Rubio,1 Emily Viau,2 and Jordan Peccia2*
Department of Civil and Environmental Engineering, Arizona State University, Tempe, Arizona 85287,1 Department of Chemical Engineering, Environmental Engineering Program, Yale University, New Haven, Connecticut 065202
*Corresponding author. Mailing address: Department of Chemical Engineering, Environmental Engineering Program, Yale University, New Haven, CT 06520. Phone: (203) 432-4385. Fax: (203) 432-4387. E-mail: jordan.peccia@yale.edu
Received October 10, 2006; Accepted May 13, 2007.

DNA-based microbial source tracking (MST) methods were developed and used to specifically and sensitively track the unintended aerosolization of land-applied, anaerobically digested sewage sludge (biosolids) during high-wind events. Culture and phylogenetic analyses of bulk biosolids provided a basis for the development of three different MST methods. They included (i) culture- and 16S rRNA gene-based identification of Clostridium bifermentans, (ii) direct PCR amplification and sequencing of the 16S rRNA gene for an uncultured bacterium of the class Chloroflexi that is commonly present in anaerobically digested biosolids, and (iii) direct PCR amplification of a 16S rRNA gene of the phylum Euryarchaeota coupled with terminal restriction fragment length polymorphism to distinguish terminal fragments that are unique to biosolid-specific microorganisms. Each method was first validated with a broad group of bulk biosolids and soil samples to confirm the target's exclusive presence in biosolids and absence in soils. Positive responses were observed in 100% of bulk biosolid samples and in less than 11% of the bulk soils tested. Next, a sampling campaign was conducted in which all three methods were applied to aerosol samples taken upwind and downwind of fields that had recently been land applied with biosolids. When average wind speeds were greater than 5 m/s, source tracking results confirmed the presence of biosolids in 56% of the downwind samples versus 3% of the upwind samples. During these high-wind events, the biosolid concentration in downwind aerosols was between 0.1 and 2 μg/m3. The application of DNA-based source tracking to aerosol samples has confirmed that wind is a possible mechanism for the aerosolization and off-site transport of land-applied biosolids.

PDF icon SnyderTestimonyforEPWSept112008.pdf28.92 KB