Jim Bynum, VP, & Gail M. Bynum, Ph.D
Help for Sewage Victims
Neither the fecal coliform test nor any laws (Solid Waste, Hazardous Waste, Clean Water) protect farmers and the public who are not being told the truth about sludge contaminated with pathogenic microorganisms. Sludge is: 1) a solid waste; 2) a hazardous waste because of E. coli and other pathogens; and 3) a point source pollutant. The current use of the fecal colifom test itself is designed to inhibit the bacterial growth so as to reduce the number of viable but culturable E. coli to less than one percent of the total. It eliminates most indicator E. coli in the sludge sample by making them viable but nonculturable by standard culture methods. This allows unknown amounts of anitbiotic resistant pathogenic superbugs to be spread on farms, parks, school grounds and even home lawns. This practice violates any government regulation for work place safety, especially laboratory safety rules.
In June 2006, EPA released the laboratory protocol , Method 1681: Fecal Coliforms in Sewage Sludge (Biosolids) by Multiple-Tube Fermentation using A-1 medium. EPA listed the following laboratory biosafety level 2 practices which must be followed to protect the workers handling and spreading sludge:
* The analyst must observe normal safety procedures required in a microbiology laboratory while preparing, using, and disposing of media, cultures, reagents, and materials, and while operating sterilization equipment.
* Field and laboratory staff collecting and analyzing environmental samples are under some risk of exposure to pathogenic microorganisms. Staff should apply safety procedures used for pathogens to handle all samples.
* "WARNING: The drying oven should be contained in a hood or be vented. Significant laboratory contamination may result from drying a heavily contaminated sample."
* Samples, reference materials, and equipment known or suspected to have viable bacteria or viral contamination must be sterilized prior to disposal.
Method 1681 is a 51 page document full of charts, graphs and mathematical formulas used to estimate the probable number of heat inhibited E. coli that could be found if the sludge was
actually completely dry. The test generates no useful information concerning the infectious nature of sludge, unless you know fecal coliform is E. coli, a pathogen. Moreover, the test ignores all other pathogenic microorganisms as well as many inorganic chemicals, synthetic organic chemicals and volatile organic chemicals which are covered elsewhere. The results of using the fecal coliform test can be seen in the increased disease levels and serious illnesses caused by bacteria, viruses, helminths, protozoa, and fungus disposed of on agricultural crops.
This is also reflect in the number of foodborne illnesses which exploded from 2 million in 1986 to 81 million case in 1997. In 1998 CDC estimated there were 360 million cases of acute diarrhea, most from unknown sources of exposure. CDC's estimate for foodborne illness was dropped to 76 million in 1999 after the Monterey Regional Water Pollution Control Agency (MRWPCA) and the Monterey County Water Resources Agency (MCWR partnership completed a $78 million project to irrigate 12,000 acres of California's best spinach and lettuce crop land in the Salinas Valley with "reclaimed" sewage water. No new numbers for foodborne illnesses have been released for the past 10 years. However, the publicized outbreaks of foodborne illnesses attributed to contaminated Salinas Valley vegetables have increased.
The Fecal coliform Test
The safety of sewage sludge and reclaimed water used on farms, parks, school grounds, home lawns and gardens is based on a 105 year old elevated temperature test to detect thermotolerant forms of E. coli in food and water, presumed to be of human fecal origin.
The fecal coliform fermentation test requires wastewater treatment plants to incubate the sludge sample at 44.5° C. (112.1° F) for 24 hours. According to EPA. "These [test] methods (1681) use culture-specific media and elevated temperature to isolate and enumerate fecal coliform organisms." Furthermore, "The predominant fecal coliform is E. coli."
In his 1904 elevated temperature test for detection of fecal contamination in food and water, Christiaan Eijkman found that elevated temperatures did not kill coli bacilli (Escherichia coli). However, he found the elevated temperature did either reduce or eliminate growth in similar types of coli. He assumed therefore thermotolerant E. coli was from warm blooded animals only and all other coli like bacteria (Enterobacteriaceae) were from cold blooded animals.
One hundred and five years later scientists have established that E. coli is the lead pathogen of the Enterobacteriaceae (coliform) family of human, animal, soil and water bacteria of which many are pathogens. Human pathogens grow best at the optimum temperature of 35-37°C (95-99°F). At this optimum temperature, with proper nutrients, E. coli doubles every 20 minutes. Therefore, in 3 hours and 20 minutes, one (1) E. coli colony forming bacteria doubling every 20 minutes would exceed the Class A requirements of 1,000 E. coli per gram by 24 bacteria. Four hours and 40 minutes later the Class B requirements of 2 million E. coli per gram would also be
exceeded. At the end of 10 hours, that one bacteria would have multiplied into 1 billion, 073 million, 741 thousand, 824 bacteria. By the end of hour 11, the number would increase to 8
billion, 589 million, 934 thousand, 592 bacteria. However, in the magical world of sludge we only have one Colony Forming Unit (CFU). The rest of the bacteria don't count.
According to preamble to part 503, "EPA concluded that the use of fecal coliform is sufficient to indicate the presence of pathogenic organisms in sewage sludge." "Fecal coliform was selected for the final part 503 regulation because an analytical method exists for fecal coliform and because treatment works conduct fecal coliform analysis routinely." (FR, 58, vol. 32, p. 9348)
In 2007 email, EPA's Mark Meckes states that "The fecal coliform group is a subset of the total coliform and it is also defined by the method used for detection. These are facultative anaerobic, gram-negative, non-spore-forming, rod-shaped bacteria that ferment lactose (specifically EC medium) with gas and acid formation within 24 hour at 44.5 degrees C."
The key words are EC medium. EC specifically refers to a culture medium used to detect E. coli. According to Perry and Hajna's study Further Evaluation of EC Medium for the Isolation of Coliform Bacteria and Eschericbia coli, (1944), EC medium was developed for the isolation of coliform bacteria at 37°C and of Escherichia coli at 45.5°C. They say, "EC medium was found highly specific for Escherichia coli at this temperature."
However, for type II E. coli, the test was only specific for 21.8% of the cultures. In the 1958 study The Coliform Group II. Reactions in EC Medium at 45° C Geldreich, et al., said, "There were 5794 cultures of coliform bacteria from untreated surface water supplies of 14 treatment plants examined. Of the 1358 E. coli included, 83.7 per cent showed positive EC reactions. When the E. coli strains are subdivided into varieties I and II (see table 1), the percentage of positive
results were 92.7 and 21.8, respectively. The remaining 10 IMViC types yielded 7.8 per cent positive tests for 4436 cultures." The coliform bacteria are typed by the name of the tests IMViC: Indole, Methyl red, Voges Proskauer, and Citrate. There are more than two types of E. coli.
E. coli 0157:H7 does not show a positive reaction in the test, yet produces a deadly shiga toxin gene (STEC ) which first appeared in a Central America Shigella outbreak. In a retroactive study, Importation of Shiga Bacillus Dysentery Into California, researchers S. BENSON WERNER, M.D., RONALD R. ROBERTO, M.D., AND JAMES CHIN, M.D., Berkeley, identified 20
cases of this unique strain of Shigella that occurred during the 1969/70 outbreak.
The first E. coli 0157:H7 case (a Naval Officer) documented with samples at CDC was in Oakland, California in 1975. The next appearance was when it was determined that E. coli 0157:
H7 shiga toxin contaminated the Jack in the Box hamburgers. The Jack in the Box hamburgers that sickened several hundred people in 1982, causing the death of four children. The Shigella like toxin (a known neurotoxin that produces delayed limb paralysis and death) was sequenced in 1986. It was noted that Escherichia coli of various serotypes, Salmonella typhimurium, and Vibrio choterae also produce the toxin. Researchers at Walter Reed Hospital had cloned the toxin producing gene by 1987.
Early scientists first acknowledged the problem with the fecal coliform test in a 1963 Public Health Service Report, SANITARY SIGNIFICANCE OF COLIFORM AND FECAL COLIFORM ORGANISMS IN SURFACE WATER, "Because no satisfactory method is currently available for differentiating fecal coliform organisms from human and other animal origin, it is necessary to consider all fecal coliform organisms as indicative of dangerous contamination." Yet, Knowing that the test temperature inhibits E. coli growth, in 2002, FDA's Bacteriological Analytical Manual Online shows an increased temperature analysis from 35-37°C (95-99°F) to 45.5°C (113.9°F) for food testing and 44.5°C." (112.1°F) for water, shellfish and shellfish harvest water analyses This test was re-designated fecal coliform.
According to Ron et al, in there study Growth Rate of Escherichia coli at Elevated Temperatures: Reversible Inhibition of Homoserine Trans-Succinylase (1971), "The preceding paper [Ron, et al.1970] showed that the growth of Escherichia coli is slowed, without killing, at 40 to 45 C, and that in the several strains tested the cause is a decrease in the activity of homoserine trans-succinylase. These temperatures are now shown to inhibit the enzyme directly, in crude extracts and after partial purification. The effect is rapid and is immediately reversible, unlike the progressive and slowly reversible changes of conventional denaturation."
In 1974 when Gerald Berg, Chief, Biological Methods Branch of the EPA's National Environmental Research Center in Cincinnati, Ohio warned of the inadequacy of the fecal coliform test, even though he implied pathogenic strains of E. coli were not part of fecal coliform. He stated:
"For some time we have been aware that fecal coliforms are not always reliable indicators for viruses and that neither fecal coliforms nor other bacteria are inviolate indicators of fecal pollution. To be sure, fecal coliforms indicate a sanitary hazard, but certain other bacteria may seem to be fecal coliforms in the standard membrane filter test. Moreover, fecal coliform may multiply in waters where pathogenic bacteria and certainly viruses cannot. And fecal coliforms may be destroyed in waters polluted with certain industrial wastes -- wastes that do not seem to affect fecal streptococci and may not affect viruses either. Clearly, it is a matter of some importance to develop a bacterial indicator system that can definitively differentiate fecal organisms from free-living forms. (p. xii)"
According to Merck's Fact Sheet, "Lactose-positive bacteria produce yellow-orange colonies and under the membrane yellow halos. The count of these typical colonies is considered to be
presumptive coliform bacteria count." "Colonies that are oxidase negative are considered to be coliform bacteria. Coliform bacteria that form indole [gas] from tryptophan at 44 ± 0,5 °C within 21 ± 3 hours are considered to be E.coli."
E. coli does not die quickly or easily. It may not die at all but be in a dormant state as in stationary phase death and heat-shock response. According to A. Eisenstark, et al, Cancer
Research Center, Columbia, MO, (1992) "When Escherichia coli cells reach stationary phase of growth, specific gene products are synthesized that protect cells while dormant. "Aged" cells
may remain viable in cultures for years. For example, agar cultures stored for 38 years still had more than10(5) [100,000] viable cells/ml. However, when specific mutants were cultured, the population of these mutants dropped sharply after 4-10 days. This defect is termed "Stationary-Phase-Death". Each mutant strain was hypersensitive to near-ultraviolet radiation and other oxidative agents. Bovine catalase rescued many of the mutants from death in dormancy,
suggesting that specific gene products protect "aged" cells against oxidative damage."
According to Fritz Schöffl, et al, Universität Tübingen, (1999), "The heat-shock response is a conserved reaction of cells and organisms to elevated temperatures (heat shock or heat stress). Whereas severe heat stress leads to cellular damage and cell death, sublethal doses of heat stress induce a cellular response, the heat-shock response, which (a) protects cells and organisms from severe damage, (b) allows resumption of normal cellular and physiological activities, and (c) leads to a higher level of thermotolerance."
In the paper, Viable but non-culturable bacteria: their impact on public health, (2005) Yogita N. Sardessai,Goa College of Pharmacy, states the problem:
"Viable but nonculturable "(VBNC) bacteria are a major concern in public health risk assessments because many pathogenic bacteria like Vibrio cholerae, Mycobacterium tuberculosis, Campylobacter jejuni, Helicobacter pylori, Vibrio vulnificus and Escherichia coli have been reported to enter a VBNC state from which they are able to return to the
infectious state after passaging in animal hosts. Reports indicate that many potentially harmful bacteria survive treatment and persist in processed food, pasteurized milk, potable water and in the environment."
"The implications of bacteria to lie in a dormant undetected state are far reaching. For instance, antibiotic resistant chronic otitis medium was earlier considered a sterile
inflammatory process. But it is now known that there are antibiotic-resistant bacteria in biofilms which are in VBNC state, causing chronic infection10. The sudden recurrence of
tuberculosis years after a person was presumed cured has also been attributed to resuscitation of VBNC Mycobacterium cells7."
James D. Oliver, Department of Biology, University of North Carolina at Charlotte, 2005, said, "It had long been assumed that a bacterial cell was dead when it was no longer able to grow on routine culture media." However, "Since the original 1982 paper from the laboratory of Rita Colwell (Xu et al., 1982), over 400 papers have appeared which describe various aspects of the phenomenon most commonly referred to as the " but nonculturable (VBNC) state" A great many pathogens, as well as nonpathogens, are now known to enter this dormancy state, and its significance in medicine, bioremediation, the use of bacteria as fecal indicators, and indeed in most microbiological studies where culturability is employed as the (often sole) indicator of viability, is becoming increasingly evident." Moreover, "a number of studies have found that
processes which are normally assumed to be bactericidal for bacteria may instead result in cells which reside in the VBNC state. These include such treatments as pasteurization of milk (e.g. Gunasekera et al., 2002) and chlorination of wastewater (Oliver et al., 2005)." Furthermore, "The number of species described to enter the VBNC state constantly increases, with
approximately 60 now reported to demonstrate this hysiological response. Included are a large number of human pathogens, including Campylobacter spp., E. coli (including EHEC strains),
Francisella tularensis, Helicobacter pylori, Legionella pneumophila, Listeria monocytogenes, Mycobacterium tuberculosis, Pseudomonas aeruginosa, several Salmonella and Shigella spp. and Vibrio cholerae, V. Parahaemolyticus, and V. Vulnificus."
Even EPA documents confirm that while heat and chemicals will cause the bacteria to be inactivated, it is a temporary condition. EPA states in (Part 403.5(b)(5)) that "Heat above 40 °C (104 °F) and disinfectants will slow or eliminate biological activity causing some bacteria to become viable, but nonculturable by standard culture methods" In effect, the test itself slows the growth of E. coli and eliminates the growth of the other Enterobacterriaceae family causing them
to become viable but nondetectable.
At the same time it ignores the following pathogenic families: 1) Aerobic Gram-Positive Cocci; 2) Aerobic Gram-Negative Cocci; 3) Aerobic Gram-Positive Bacilli; 4) Aerobic Gram-Negative Bacilli: Nonenterobacteriaceae—Fermentative; 5) Aerobic Gram-Negative Bacilli: Nonenterobacteriaceae—Nonfermentative; 6) Aerobic Gram-Negative Fastidious Coccobacilli; 7) Mycoplasma (Pleuropneumonia-Like Organisms [PPLO]); and 8) Treponemataceae (Spiral Organisms).
These families of bacteria contain the most deadly community acquired superbugs. Among these are the Invasive group A streptococcal, Staphylococcus, MRSA, Clostridium, most
Necrotizing (flesh eating) bacteria, and E. coli 0157 which have become epidemic. It also ignores the deadly community acquired viruses such as swine flu, Adenoviruses, arenaviruses,
Herpes viruses, paramyxoviruses, papovaviruses such as Polyoma virus and Papillomasvirus, picornaviruses such as enteroviruses, Poliovirus, Coxsackievirus, Echovirus, and hepatitis A virus.
In a February 2009, e-mail EPA's Richard Reding, Chief, Engineering and Analytical Support Branch, pointed out that the heat inactivation of most E. coli and reduction or eliminating other similar bacteria from the test was by design when he wrote that fecal coliform "are distinguished from the coliform group by their ability to grow at the elevated temperature of 44.5°C. Thus, "inactivation" is by design so as to eliminate those bacteria that are unable to grow at 44.5°C
According to a July 2007 study, the fecal coliform test would specifically reveal, with the exception of 0157, some heat inhibited thermotolerant E. coli strains. Strains growing in drinking water systems at elevated temperature were, 1) 04 Uropathogenic E. coli,UPEC); 2) 025 Enterotoxigenic E. coli, ETEC); 3) 086 (Enteropathogenic E. coli, EPEC); 4) 0103 (Shiga-toxin producing E. coli, STEC); 5) 0157 Shiga-toxin producing E. coli, STEC); 6) 08 Enterotoxigenic E. coli, ETEC); and 7) 0113 Shiga-toxin producing E. coli, STEC).
CDC documents indicate the infective dose for E. coli is estimated to be only 10-100 non-heat stressed organisms. E. coli doubles every 20 minutes, which means that if you are infected with only one bacteria, in 2 hours you are well past the infection stage.
Other non-0157 serotypes of E coli –eg O29, O39, O145 produce shiga-like toxins, causing bloody inflammatory diarrhea, evoking Hemolytic uremic syndrome (HUS). According to the
Oklahoma Department of Health, enterohemorrhagic Campylobacter, Shigella, Salmonella, and Yersinia may cause Hemolytic uremic syndrome (HUS) , a disease that destroys red blood cells and causes kidney failure, primarily affecting children. Furthermore, according to the Department of Health, "Not all cases of HUS are caused by shiga toxin; while uncommon, a variety of viral and bacterial infections, as well as some cancers, can cause HUS" Hospital cost for a HUS victim is about $100,000.00. Between 8% of HUS victims treated without antibiotics and 50% treated with antibiotics die.
According to Meridian Bioscience, STEC infections are very serious because: 1) Antibiotics increase Shiga toxin release and production and should be avoided: 2) HUS [Hemolytic uremic
syndrome] develops in 56% of STEC patients treated with antibiotics; 3) HUS develops in only 8% of STEC patients not receiving antibiotics; 4) 38%-61% of patients with STEC infection will develop Hemorrhagic Colitis; 5) 5%-10% of patients with STEC infection will develop HUS; 6) Approximately 10% of those with HUS will die or have permanent renal failure; 7) 30%-50% of all STEC infections are caused by E. coli non-O157; 8) 50% of HUS cases are caused by non-
O157 strains of E. coli; 9) SMAC culture misses as much as half of all O157:H7 and all non-O157 strains of E. coli; and 10) Hospital cost of care for one HUS is approximately $100.000.
The reality is that the only thing the fecal coliform test proves is that there are an unknown quantity of viable pathogens in sludge. While there may be some non-pathogenic strains, the International Escherichia and Klebsiella Centre (WHO) has a collection of approximately 60,000 E. coli strains, most of which are clinical isolates. No one has any idea how many or what type of unknown and viable but nonculturable pathogens are in sludge and reclaimed water when the test sample is drawn, much less after the test is completed due to the elevated temperature of the test.
The number of these thermotolerant E. coli strains that survive the heat and react to EC medium (two million CFU per gram (0.035273 oz) Most Probable Number (MPN) dry weight -
Class B and 1,000 CFU per gram - Class A) allowed in sludge are mathematical assumptions based on charts and graphs of heat inhibited growth of E. coli bacteria in sludge and the density of the sludge being converted from liquid to total solids. The CFU refers to the number of bacterial colonies technicians are able to count after 24 hours. The Most Probable Number used for classifying sludge is the assumed number of original bacteria spiked in the test 24 hours
earlier. Meaning that each colony is counted as one bacteria at the start of the test. That does not included bacteria tightly bound in biofilms. For Class B sludge that is 56,000,000 E. coli colonies of bacteria per ounce of sludge or 9,072,000,000 E. coli colonies of bacteria per pound of sludge. After undergoing further treatment to reduce pathogens with chemical or heat treatment for Class A sludge that is 28,350 heat inhibited E. coli Colonies of bacteria per ounce
of sludge or 453,600 heat inhibited E. coli colonies of bacteria per pound of sludge biosolids. Contrast that with the two to 10 most probable number of E. coli Colonies per gram (0.035273 oz) allowed in swimming water. There is no provision to protect water from receiving bacterial contaminated runoff from sludge sites since they are considered by the enforcers of the Clean Water Act to be unregulated non-point sources of pollution.
Using this outdated test proponents of sludge use claim it proves sewage sludge is safe for use as a fertilizer on food crops, school grounds and your lawn if only a few bacteria are found. The problem is that the elevated temperature test itself inhibits or stops the growth of bacteria in the sample, while the pathogens in the original material continue to thrive at normal temperatures.
This test does not offer any protection from contamination of our air, food supply, drinking water, or health as part 503 only discusses pathogen reduction, not elimination. This is
accomplished by the test itself as we discovered when our farm was contaminated by sludge runoff. This was mentioned in the article Sludge Magic at EPA). Lewis checked with the laboratory to confirm the fecal coliform levels were low but Salmonella and E. coli levels were high. While several tests were done for fecal coliform, the two tests specifically for E. coli and Salmonella are the most important. However, at the time we did not realize fecal coliform is E.coli whose growth is inhibited by the elevated test temperature.
Bacteria do not die just because sludge has been treated. In the study Occurrence of Pathogens in Distribution and Marketing Municipal Sludges (1988) William A. Yanko, County
Sanitation Districts of Los Angeles County, tested seven municipal sewage sludge compost products. They were sampled weekly for one year. He found "significant increases in bacterial populations, including salmonellae, occurred during subsequent production of commercial soil amendment products."
Treatment causes some of the pathogenic disease organisms to be absorbed or enclosed in fecal particles during the treatment process. These are biofilms holding the particles together. For this reason, In the study "Survival of pathogenic micro-organisms and parasite in extreta, manure and sewage sludge" (1991) D. Strauch, Institute of Animal Medicine and Hygiene, University of Hohenhiem, warned, "the agricultural utilization of hygienically dubious sewage sludge poses a risk for the whole national economy."
After reviewing the sludge rule and laboratory reports from our farm, EPA's own David Lewis warned about the danger to public health from bacterial survival on farms in the article Sludge Magic at the EPA (1999). He said, "the Sludge Rule on land application of municipal wastes (40 CFR Part 503) promulgated in 1993 may be the most scientifically unsound action ever taken by the agency. Rather than being protective, the rule actually threatens public health and the environment."
Lewis et al, documented the danger to public health from microorganisms in the study, Interactions of pathogens and irritant chemicals in land-applied sewage sludges (biosolids)
(2002). David L Lewis, David K Gattie , Marc E Novak , Susan Sanchez and Charles Pumphrey. They found, "Affected residents lived within approximately 1 km of land application sites and generally complained of irritation (e.g., skin rashes and burning of the eyes, throat, and lungs) after exposure to winds blowing from treated fields. A prevalence of Staphylococcus aureus infections of the skin and respiratory tract was found. Approximately 1 in 4 of 54 individuals were infected, including 2 mortalities (septicaemia, pneumonia)."
A 2007 epidemiologic self reporting survey of neighbors near an Ohio biosolids (sludge) site by researchers from the University of Toledo revealed excessive health problems. The Health Survey of Residents Living Near Farm Fields Permitted to Receive Biosolids (2007), Sadik Khuder, PhD; Sheryl A. Milz, PhD; Michael Bisesi, PhD; Robert Vincent, PhD; Wendy McNulty, MS; Kevin Czajkowski, PhD, found that the, "Results revealed that some reported health-related symptoms were statistically significantly elevated among the exposed residents, including excessive secretion of tears, abdominal bloating, jaundice, skin ulcer, dehydration, weight loss,
and general weakness. The frequency of reported occurrence of bronchitis, upper respiratory infection, and giardiasis were also statistically significantly elevated. The findings suggest an increased risk for certain respiratory, gastrointestinal, and other diseases among residents living near farm fields on which the use of biosolids was permitted." The permitting is all based on a fecal coliform test going back to 1904
The fecal coliform test that is used as an indicator for fecal contamination of food and water does not protect the farmers and the general public from deadly bacteria, viruses, worms,
protozoa or fungus found in sludge, a fecal material. Fecal coliform refers to one member of the coliform (Enterobacteriaceae) family -- thermotolerant types of E. coli, but does not include E. coli 0157:H7 . This test offers no protection for public health based on the following facts: 1) most pathogens grow well at normal temperatures: 2) thermotolerant fecal coliform includes many pathogenic strains of E. coli and similar bacteria while excluding all other viable but nonculturable aerobic and facultative bacteria that thrive at normal temperatures; 3) E. coli is the primary coliform resistant to heat inactivation and the test doesn't indicate heat resistant toxins; 4) biofilms tightly bind pathogens together in sludge particles causing them to be
invisable; 5) heat, chemicals or drugs stresses may damage some E. coli DNA causing it to become dormant (be nonculturable-nondetectablle) by standard cultural methods -- only to be revived by its SOS Response genes; 6) dormant, but viable E. coli cells have survived in storage for 38 years; 7) the test does not indicate viruses and parasites; and 8) bacteria and viruses exchanges genes during the sewage treatment process creating more powerful antibiotic resistant strains of pathogens.
Farms and associated business are damaged or destroyed, surface and ground water are contaminated, animals and people are sick, dead and/or dying based on a 105 year old test
that proves pathogen contaminated sewage sludge is being disposed of as a fertilizer or soil amendment. Based on twenty years of research, there is currently no scientific or management method which would safely allow the use of sludge or reclaimed water on legitimate farming operations for any reason or for any other public purpose.