INTRODUCTION TO SEWAGE SLUDGE VICTIMS

hshields@tds.net                                                                                                                updated 5/25/2011

WHY does sewage sludge make people sick?

NEIGHBORS of sludge sites are frequently subjected to a noxious miasma of toxic/irritant gases, airborne
particulates, allergens  and  pathogens including viruses, bacteria, endotoxins, molds, and fungi.

The U.S. Environmental Protection Agency (EPA) acknowledges sewage sludge emits toxic/irritant gases including  
Dimethyl  Sulfide, Dimethyl Disulfide, Methyl Mercaptan, Trimethylamine, Ammonia. and others.  (http://www.barc.
usda.gov/nri/smsl/temp/appendix.pdf)

The Centers for Disease Control (CDC), Occupational Safety & Health Administration (OSHA) National Institute of  
Occupational Safety and Health (NIOSH), Department of Transportation (DOT) and the Agency for Toxic Substances
and  Disease Registry (ATSDR) all warn that these gases  can pose significant risk to human health through
"ingestion, inhalation
or skin absorption."  (“Ingestion” includes ‘inhalation of bioaerosols, which are deposited in the throat and upper
airway and swallowed.”)   Target organs:  Eyes, skin and respiratory system.

Symptoms from exposure to these gases can include irritation of the skin, eyes, nose and throat,  headache,
nausea,  vomiting, wheezing, coughing, shortness of breath, irregular heartbeat, respiratory distress,
bronchospasm,  and in worst cases,  laryngospasm, laryngeal edema, pulmonary edema and chemical pneumonitis.

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Oft-repeated waste industry myths are that sewage workers don't get sick from exposure to sludge, and the
symptoms  suffered by neighbors of sludge sites  are "psychosomatic" .

In 1998 the National Institute of Occupational Safety and Health (NIOSH) issued Health Hazard Evaluation Report
No.  98-0118-2748 regarding pathogenic bioaerosols emitted by sewage sludge.

NIOSH noted sludge workers reported abdominal cramps, loose bowel movements, intermittent episodes of various  
gastrointestinal symptoms, abdominal cramping and headaches.

NIOSH concluded:  The detection of enteric bacteria in the air and bulk samples collected in this HHE confirms the  
potential for sewage workers to be occupationally exposed to organisms which have been associated with
gastrointestinal symptoms/illnesses.

"The total bacterial concentrations detected in the air were similar to those found in the one study of airborne
microorganisms from land application of sewage sludge."

"The three single CFU plates grew Burkholderia, Aeromonas-like, and Klebsiella-like bacteria (identified to genus
level).   The multi-CFU plate grew Burkholderia and Enterobacter agglomerans.  All of these are Gram-negative
bacteria.  Bacteria in the Burkholderia genus and Enterobacter agglomerans are opportunitistic human pathogens
(immunocrompromised persons are more susceptible to these organisms)."

"While the specific component(s) of the sewage sludge responsible for the employees' symptoms have not been
determined,  the nature and timing of the symptoms suggest occupational exposure by inhalation or ingestion of the
biosolids as a probable cause."

"The environmental monitoring data show that contaminated aerosols may be produced during the work process; the
potential for respiratory exposures also exists ...."

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IN AUGUST 2000, NIOSH issued another Hazard Identification Report 2000-158 regarding workers exposed to Class
B sewage sludge during and after field application.

"All five employees reported at least one episode of gastrointestinal illness after working with the biosolids, either at
the treatment plant or during land application."

"The environmental sampling results indicated that the gastrointestinal illnesses were possibly of occupational origin."

"NIOSH collected bulk samples from different locations within the biosolids storage site.   The mean fecal coliform
concentration of the bulk samples was 220,000 CFU per gram of sample (wet weight).    Fecal coliforms are used as
an indicator for the presents of other enteric microorganisms."

"THERE REMAINS A SIGNIFICANT EXPOSURE RISK."

"These enteric organisms are usually associated with self-limited gastrointestinal illness but can develop into more
serious diseases in sensitive populations such as immunocompromised individuals, infants, young children, and the
elderly."

"NIOSH collected air samples for bacteria and endotoxin (a component of some bacteria), and bulk sewage sludge
samples for fecal coliform bacteria at a Class B biosolids land application processing facility.   Potentially pathogenic
bacteria were found in bulk samples and in some air samples.    Employee gastrointestinal illnesses at that facility
may have been caused by ingestion or inhalation of Class B biosolids. "

"Appropriate personal protective equipment should be required for all job duties likely to result in exposure to Class
B biosolids.  The choices of personal protective equipment include goggles, splash-proof face shields,
RESPIRATORS, liquid-repellant coveralls, and gloves".
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[NEIGHBORS of sludge sites unfortunately are not warned that they too may need respirators.]

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In an Ecological Risk Assessment "Bioaerosol Transport Modeling and Risk Assessment in Relation to Biosolid
Placement" by Scot E. Dowd, Charles P. Gerba, Ian Pepper and Suresh Pillai, published in the Journal of
Environmental Quality 29:343-348 (2000) the authors stated:  

"There is growing concern regarding exposure to microbial pathogens from biosolids via aerosols, especially in
population centers surrounding biosolid application sites.  (Dowd et al, 1997)  This is a valid concern because
aerosols can transmit many enteric microorganisms (Pahren and Jakubowski, 1980)."

"Based upon the estimated bioaerosol release rates, we can apply bioaerosol concentrations and microbial
inactivation rates to model transport data and obtain the risk factors associated with breathing air contaminated by
microbial pathogens originating from biosolid material."

"The typical route of exposure for organisms that are primarily associated with intestinal infection is based upon the
inhalation of bioaerosols, which are deposited in the throat and upper airway and swallowed (Wathes et al, 1988)."

"Additionally, inhaled enteric pathogens may establish throat and respiratory infections that can increase the risk of
swallowing an infectious dose (Clemmer et al, 1960)."

"...the potential for an increased risk of work-related illness in such biosolid workers is collaborated (sic) by
numerous epidemiological studies which have shown higher rates of illness in wastewater workers."

"Clinically, these illnesses were usually manifested as undue tiredness and headaches that were evident after work.   
Additionally, other symptoms such as respiratory problems, nonspecific bowel dysfunction, irregular heartbeat,
nausea, vomiting, and diarrhea were also common complaints."

The ABSTRACT of the Bioaerosol Risk Assessment focuses on  the (obvious) conclusion that healthy people who
live 6.2 miles from the sludge site are at no risk from sludge bioaerosols.     However,  a closer reading of the Tables
indicates significant risk to people living within 3/4 of a mile of a sludge site .

For example, the exposure risk  from  airborne bacteria originating in a sludge stockpile to people who live within
1640 feet and have their windows open day and night (such as in the summer) with a wind speed of 11 mph is 400
out 10,000 -- far in excess of  EPA's "acceptable risk" of one out of 10,000.

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In a 1993 report "HAZARDS FROM PATHOGENIC MICROORGANISMS IN LAND DISPOSED SEWAGE SLUDGE"  by
Timothy Straub, Ian Pepper and Charles Gerba (Reviews of Environmental Contamination and Toxicology, Vol. 132),
the authors made the following statements about sludge bioaerosols (pages 71 and 72):

"Many enteric microorganisms can effectively be transmitted by aerosols. . . . Organisms in such aerosols can be
transmitted by inhalation . . ."

"The number of microorganisms in aerosols depends on the type of sludge disposed, method of application, and
number of microorganisms in the sludge.    The greatest amount of aerosol generation would occur during the
application of sludges with a low solids content applied as slurries during spray application.     Dumping of sludges
from trucks onto the soil or into trenches
and area fills would also generate aerosols on impact."

"Some aerosoling would occur during the application of sludge.     Greater numbers of pathogenic microorganisms
would be aerosoled during disposal of primary rather than treated sludges."

"If wind velocities at a site are great enough, suspension sludge particles could occur (USEPA  1986).    Most
sludges would not be easily resuspended because of their moisture content and tendency to mat as they try."

"Dried sludges, however, may be very light and fine in texture and, therefore, easily resuspended.   If dried sludge is
not covered at windy sites, winds will attain speeds capable of suspending the sludge from the working face."

"Aerosols could (also) be transported downwind to exposure areas distant from the disposal site. "

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AFTER Dr. Charles  Gerba was hired as an expert witness to testify on behalf of the sludge company
(Synagro/Biogro/Waste Management)  in the pending lawsuit regarding  the death of 26 year old Shayne Conner
from exposure to sludge in Greenland, NH, in 1995,  Dr. Gerba  made the following statements:

"The pathogens found in biosolids are primarily transmitted by ingestion and not inhalation."

"The organisms found in biosolids primarily infect the intestinal tract and are referred to as enteric pathogens for
that reason.   They cause diarrhea or other intestinal problems."

"Enteric bacteria . . .  are not usually transmitted by aerosols."

"No transmission of enteric pathogens by aerosols from biosolids has been reported in the scientific literature."

Dr. Gerba also said the pathogens "die off quickly".

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US EPA publication  - "CONTROL OF PATHOGENS AND VECTOR ATTRACTION IN SEWAGE SLUDGE - 1999"
appears to contradict Dr. Gerba.

Page 9:

"How could exposure to these (sludge) pathogens occur?"

"Direct Contact ......Inhaling microbes that become airborne (via aerosols, dust, etc.) during sewage sludge
spreading or by strong winds, plowing, or cultivating the soil after application."

Survival time of pathogens in soil - bacteria and viruses "absolute maximum, one year".

THUS, Dr. Gerba's statements declaiming airborne transport of sludge pathogens which he recently made in
December 2000, as an expert witness for the sludge company, appear to contradict statements he made in his
earlier works in 1993 and January 2000, as well as the conclusions of NIOSH and the USEPA.

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In responding to  Dr. Gerba, Microbiologist Dr. David Lewis notes:

"In his affidavit, Dr. Gerba states that pathogens in sludge are primarily transmitted by ingestion and not inhalation.   
Yet his published estimates of risks of infection . . . were quantified by modeling aerosolized concentrations of
microbial pathogens at a given distance from the source and the numbers inhaled over a given period of time."

" . . .Dr. Gerba testified that he has not been able to detect airborne, sludge-associated pathogens during
application of liquid sludge (2-3% solids) and that this application method is more prone to generate airborne
pathogens than chain-dragging the dried material with tractors . . . . . Even without relying upon the wealth of
scientific literature on transmission of pathogens by dust particles, most lay persons are familiar through personal
experiences with the fact that dust from dry, non-vegetated fields is carried even great distances by strong winds
and can cause respiratory illness."

"Class B sewage sludge that dries out and becomes airborne during chain dragging, or as strong winds blow over
non-vegetated lands where solid sludge has been applied - especially within the previous 30 days - is more of a
threat to public health than liquid aerosols."

"In any suspension, most microorganisms, by far, are attached to the surfaces of solid particles . . .   simply by virtue
of the fact that most pathogens in sludge are attached to solid particles   . .. . . . . most anyone can understand that
airborne dust particles contain much higher numbers of bacteria and viruses than liquid aerosols for comparably
sized particles."

"Gerba's arguments that pathogens on dust from sludge pose virtually no threat because they quickly die off
neglects the fact that many of the symptoms experienced by people who inhale or ingest Class B sludge particles
are actually enhanced by bacterial cell death."

"Endotoxins, which account for gastrointestinal symptoms and various effects on the respiratory system, are
liberated when gram negative bacteria die.    Antibiotic therapy for patients infected with gram negative bacteria
sometimes carries a high risk of mortality from endotoxins released as the bacteria die away after administering
antibiotics."

"When Class B sludge is not incorporated into soil, organic aggregates that form dust particles carry a double
whammy:  an outside coating of endotoxins from dead gram negative bacteria plus an inner core of viable
pathogens.    When these particles are ingested or inhaled, bodily processes break down the aggregates, releasing
both endotoxins and viable pathogens."

http://members.aol.com/lewisdavel/Expertreport.htm

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THE REPORT "POTENTIAL HEALTH EFFECTS OF ODOR FROM ANIMAL OPERATIONS, WASTEWATER
TREATMENT AND RECYCLING OF BYPRODUCTS", Dr. Susan Schiffman, Duke University and Dr. John Walker,
USEPA, lead authors, published in the November 2000 issue of the Journal of Agromedicine supports Dr. David
Lewis' research and helps to explain why neighbors of sludge sites (as well as sludge workers) are getting sick.

"Complaints of health symptoms from ambient odors have become more frequent in communities with confined
animal facilities, WASTEWATER TREATMENT PLANTS, AND BIOSOLIDS RECYCLING OPERATIONS."

"The most frequently reported health complaints include eye, nose, and throat irritation, headache, nausea,
diarrhea, hoarseness, sore throat, cough, chest tightness, nasal congestion, palpitations, shortness of breath,
stress, drowsiness, and alterations in mood."

"Odors are sensations that occur when a complex mixture of compounds (called odorants) stimulate receptors in the
nasal cavity.    Most odorants associated with animals manures AND  BIOSOLIDS are volatile organic compounds
(VOC's) that are generated by bacterial degradation of protein, fat, and carbohydrates in the organic matter.  
Reactive inorganic gases such as AMMONIA and hydrogen sulfide are also important odorants that can be emitted
from animal manures AND BIOSOLIDS. " (pg. 8)

"In the first paradigm, the symptoms are induced by exposure to odorants at levels that also cause irritation (or other
toxicological effects).   That is, irritation -- rather than the odor -- is the cause of the  symptoms, and odor simply
serves as an exposure marker. "

"In this paradigm irritancy (or other toxicity) generally occurs at a concentration somewhat higher (about 3 to 10
times higher) than the concentration at which odor is first detected (odor threshold)."

"While the concentration of each individual compound identified in odorous air from agricultural and municipal
wastewater facilities seldom exceeds the concentration that is known to cause irritation, the combined load of the
mixture of odorants can exceed the irritation threshold.   That is, the irritation induced by the mixture derives from the
addition (and sometimes synergism) of individual component VOCs."

"In the second paradigm health symptoms occur at odorant concentrations that are not irritating.   This typically
occurs with exposure to certain odorant classes such as sulfur-containing compounds and organic amines at
concentrations that are above odor detection thresholds but far below irritant thresholds."  (pg. 9)

"Health symptoms often reported include a stinging sensation, nausea, vomiting, and headaches.   The mechanism
by which health symptoms are induced by sulfur gases or organic amines for which odorant potency far exceeds the
irritant potency is not well understood."

"In the third paradigm, the odorant is part of a mixture that contains a co-pollutant that is essentially responsible for
the reported health symptom.   Odorous airborne emissions from confined animal housing, COMPOSTING
FACILITIES, AND LAND APPLICATION OF SLUDGE can contain other components that may be the cause of the
symptoms such as
bioaerosols consisting of endotoxin, dust from food, airborne manure particulates, glucans, allergens,
microorganisms, or toxins."  (pg. 10)

"The odor exposures that have received the greatest research attention are those that involve irritation.   
Physiological responses to irritation in the upper respiratory tract (nose, larynx) and/or lower respiratory tract
(trachea, bronchi, deep lung sites) have been documented in both humans and animals."

"Irritation of the respiratory tract can alter respiratory rate, reduce respiratory volume (the amount of air inhaled),
increase duration of expiration, alter spontaneous body movements, contract the larynx and bronchi, increase
epinephrine secretion, increase nasal secretions, increase nasal airflow resistance, slow the heart rate, constrict
peripheral blood vessels, increase blood pressure, decrease blood flow to the lungs, and cause sneezing, tearing,
and hoarseness."  (pg. 12)

"Health symptoms  from odors can potentially result from two sources:   the odor (the sensation) or the odorant (the
chemical or mixture of chemicals that happens to have an odor)."  

"PHYSIOLOGICAL SYMPTOMS CAUSED BY SENSORY IRRITATION

"Administration of irritant compounds to the upper and/or lower airway in laboratory studies produces many systemic
responses including:  (1)  changes in respiratory rate, depending upon the primary level of irritation (upper versus
lower), (2)  reduced respiratory volume, (3) increased duration of expiration, (4) alterations in spontaneous body
movements, (5) contraction of the larynx and bronchi, (6) increased epinephrine secretion, (7) increased nasal
secretion, (8) increased nasal airflow resistance, (9) increased bronchial tone, (10) decreased pulmonary
ventilation, (11) bradycardia, (12) peripheral vasoconstriction, (13) increased blood pressure, (14) closure of the
glottis, (15) sneezing, (16) closure of the nares, (17) decreased pulmonary blood flow, (18) decreased renal blood
flow and clearance, and (19) lacrimation or tearing."

"Irritants can also induce hoarseness of voice and impair mucociliary clearance functioning. " (pg. 19)

"Odorous VOCs have been found in the blood and brain after three hours of exposure, and olfactory receptors have
been shown to respond to blood-borne odorants." (pg. 22)

"Health complaints do occur at levels of VOCs that are below irritant thresholds."

"According to the World Health Organization (WHO), the definition of "health" is
"...a state of complete physical, mental, and social well-being and not merely the absence of disease or infirmity."    
Thus, a symptom that diminishes physical, mental, or social well -being would be a "health effect" according to WHO."

"The majority of the participants at the Health Effects of Odors workshop considered it appropriate to explore health
effects of odors within the WHO definition of health."

"Frist emphasized that reactions to odors such as nausea, headache, loss of sleep, and loss of appetite clearly
represent a matter for public-health concern and attention under the WHO definition of health. "(pg. 29)

"EVIDENCE FOR PARADIGM 3:  A CO-POLLUTANT IN AN ODOROUS MIXTURE IS RESPONSIBLE FOR THE
REPORTED HEALTH SYMPTOM " (pg. 31)

"AIRBORNE DUST PARTICLES CAN CONCENTRATE ODORANTS SUCH AS ORGANIC ACIDS AND AMMONIA ON
THEIR SURFACES; this contributes to odor potential and exacerbates irritancy induced by dust in the respiratory
tract.  Experimental studies have found a strong link between odor/irritation intensity and levels of particulates."

"PARTICULATES ASSOCIATED WITH FECAL WASTE ARE ALSO KNOWN TO CARRY BACTERIA.     Thus, it is
likely that some of the health complaints ascribed to odor may, in fact, be caused by particulate matter (liquid or
solid) suspended in air or by a synergistic effect between odorants and particulates."

"A SYNERGISTIC EFFECT OF AMMONIA AND DUST EXPOSURE has been reported in a study of 200 poultry
facilities.   The adverse health effects of ammonia and particulates in combination was greater than the additive
effect of ammonia and particulates by a factor of 1.5 to 2.0."

" Both fine and coarse particles in an odorous plume enter the nasal cavity and can induce nasal irritation.    
However, these particles differ in the degree to which they traverse the respiratory tract."

"Fine particles include particulate matter with sizes less than 2.5 uM (PM 2.5).  These particles are more likely than
coarse particles to cause respiratory health effects because they reach the gas-exchange region of the lung."

"ULTRA-FINE PARTICLES (i.e. THOSE WITH A DIAMETER 0.1uM OR LESS) MAY BE EVEN MORE TOXIC THAN
LARGER SIZED PARTICLES PRODUCING SEVERE PULMONARY INFLAMMATION AND DAMAGE AND EVEN
AFFECTING MORTALITY."   (pg. 31)

PAGES 57-58 - FINAL COMMENTS

Our current state of knowledge clearly suggests that it is possible for odorous emissions from animal operations,
wastewater treatment and RECYCLING OF BIOSOLIDS to have an impact on physical health.

The most frequently reported symptoms attributed to odors include eye, nose and throat irritation, headache,
nausea, hoarseness, cough, nasal congestion, palpitations, shortness of breath, stress, drowsiness, and alterations
in mood.

Many of these symptoms (especially irritation, headache, hoarseness, cough, nasal congestion, and shortness of
breath) can be caused by stimulation of the trigeminal nerve in the nose at elevated levels of odorous VOCs.


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ON OCTOBER 13, 1994, 11 year old Tony Behun rode his dirt bike through freshly applied sewage sludge on a strip
mine site in Rush Township, Pennsylvania.  He returned home covered head to toe with black, putrid smelling
material.   His mother had him remove his clothes in the garage and bathe immediately.  She hosed his bike off to
remove the sludge.

TWO DAYS LATER Tony had a lesion on his arm and leg, a sore throat, fever,  vomiting and headache.  Six days
later he was in a hospital emergency room, his fever climbing.   The child was then rushed by helicopter to Allegheny
General Hospital in  Pittsburgh where he died the next morning from a virulent Staphylococcus Aureus infection . . .   
8 days after he rode his bike
through the sludge.

The Pennsylvania Department of Environmental Protection (DEP) first blamed Tony's death on an infected bee
sting.  Subsequently, they apologized for this false statement.     Later they suggested he was infected by  sewage in
a creek or a chipmunk bite.  Then they claimed the Staphylococcus Aureus  which killed Tony is not a pathogen
found in sludge.   (It is - see EPA's Pathogen Risk Assessment Methodology for Municipal Sewage Sludge Landfilling
and Surface Disposal" PA/600/R-95/016 August 1995. )

In yet another misstatement of the truth, the PA DEP went on television November 15, 2000 and stated "NIOSH
investigated the case and concluded Tony's death was not caused by sludge."  (Totally false - never happened --
NIOSH only concerns itself with work related health and safety issues.)

Continuing their inept investigation, the PADEP recently  went to the sludge site, took a sample of the  6-YEAR OLD
SLUDGE,  had it analyzed,  and announced on their web page that there was no Staphylococcus Aureus in the
sludge .  (As previously indicated, US EPA says one year is the absolute maximum for survival of sludge viruses and
bacteria in soil.)

Microbiologist  David L. Lewis, PhD stated in an email to Dr. Joel Hersh of the Pennsylvania Dept. of Health:

"An otherwise healthy 11-year old boy rides his motorbike across a mining area ankle deep in sewage sludge."   
"Within hours he develops lesions on an arm and a leg, runs a high fever within two days, and is dead in eight days
from Staph aureus septicemia."

"It shouldn't be surprising that covering a child with wet caustic sewage sludge (containing strong irritants to skin, e.
g. lime, ammonia, organic amines) is likely to give him a superficial Staph infection that may progress to
septicemia.     (Some of the Staph comes from what gets flushed down toilets in hospitals where people are being
treated for virulent strains of the
organism, and what goes into sewer lines from mortuaries where they drain all the bodily fluids.)"

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IN THE DARK OF NIGHT in October 1995, a convoy of tractor trailer trucks rolled through a sleeping residential
neighborhood in Greenland, New Hampshire, and dumped 650 tons of biologically active, "lime stabilized" Class B
sewage sludge from Portland, Maine, on adjacent hay fields.

Residents of the neighborhood awoke to a stomach-wrenching stench, which was followed by weeks  and months of
sickness ...... and death for a 26 year old man, Shayne Michael Conner.

 A Case Study of Enhanced Susceptibility to Infection From Exposure to Gases Emitted by Sewage Sludge, by David
L. Lewis, Samuel Shepherd, David K. Gattie, Susan Sanchez and Marc Novak, concludes:

" ABSTRACT:  Most of twenty residents living in a Greenland, NH, neighborhood where Class B biosolids were
applied in 1995 experienced severe irritation of the eyes, skin, and mucous membranes, followed by respiratory and
gastrointestinal illnesses.

A 26-year old male died during one episode of respiratory distress approximately six weeks after the application.    
Laboratory tests and mathematical model outputs show that residents were probably exposed to at least 260 parts
per million (ppm) of ammonia and 110 ppm of dimethyl disulfide emitted by the biosolids.

Residents were also exposed to biosolids dust containing significant numbers of opportunistic bacterial pathogens
known to cause respiratory illnesses.   Symptoms, which included severe irritation to mucous membranes followed by
respiratory infections. are consistent with enhanced susceptibility to infections after exposure to irritant gases. "

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.
Typical of EPA's disdainful attitude towards sludge victims are the instructions to "investigators" of sludge odors
caused by the toxic/irritant gases emitted by sewage sludge, contained in the "EPA/USDA  Field Guide to Stockpiling
Biosolids, Appendix A" (page 91):

"Odorous air sampling shall be performed upon the complainant's property.   The inspector shall work independent
of the complainant; results shall be released after a written report is filed.   The inspector shall not conduct the
odorous air sampling if the complainant is present."

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 EPILOGUE

   The people sickened by the sludge plague are victims of germ warfare being waged against them by
the waste industry and US EPA.   They are forcibly subjected to this biologically active infectious waste
against their will.  Sludge pollutants are trespassing into their air, land and water. . . indeed, right into
their homes.      Their health, property values and quality of life are being destroyed by these powerful
entities who dismiss them as "acceptable risks".

   Sludge victims are told by the public agencies who should be protecting them that they are hysterics,  
hypochondriacs and their illnesses are "psychosomatic"    Victim after victim say that when they
appealed to local, state and federal agencies for help, their pleas fell on deaf ears.     "No one cared" . . .
"No one would listen".   "The EPA says it's safe so it can't be  making you sick".

    Many victims told me, "The person who owns the land where they are spreading the sludge is rich,
powerful, politically influential.    He doesn't live here so he is not affected . . . we are afraid to go up
against him."

   Land spreading is the cheapest way to get rid of sludge, saving cities and POTWs millions of dollars
over the cost of land filling or other disposal methods.     Also, many property owners are being paid to
put sludge on their land.    Thus, the EPA's sludge policies are driven by financial interests which
supersede any concern for the  health and well being of the neighbors.

   Another reason sludge victims may be  treated with disdain and contempt by the waste industry and
EPA is because they usually are people of modest financial means living in sparsely populated areas
with little or no political clout.    No sludge is land spread in well-to-do communities.    Thus, the land
spreading of sewage sludge is an issue of environmental injustice -- the infliction of polluting facilities
or environmentally degrading activities on Rural Americans who do not have the money or political
connections to fight back.

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