To the reader:
The information about sludge victims in this booklet is just the tip of the iceberg. The U. S. Environmental Protection
Agency (EPA) has refused all FOIA (Freedom of Information Act) requests about complaints of odors and/or harm to
human health, pets, farm animals, wildlife, fish, land, surface and ground water, etc. from the landspreading of
On October 30, 1997, Dr. Alan Rubin, author of the 40 CFR Part 503 sludge rules, called me on the telephone in
response to my Freedom of Information Request (FOIA) and told me EPA lawyers said he could charge me $42,000
for release of this information. He said $1500 of that amount would be for Xeroxing 10,000 pages at 15 cents a page.
IF, as the EPA and waste industry claim, there are "no sludge victims" -- what is contained in those 10,000 pages?
Dr. Rubin told me "freedom of information" doesn't mean "free" information. He said providing me with this
information at no charge would be a misuse of taxpayer funds. I asked about EPA giving taxpayer funds to the WEF
(Water Environment Federation - whose members produce and landspread the sludge) to debunk and discredit
sludge victims -- wasn't that a
misuse of public money? Dr. Rubin would not answer that question..
Dr. Rubin told me he was aware of "thousands of allegations" (regarding sludge problems).
I asked how EPA handled these allegations? He said EPA "responded" to sludge complaints. (A few months later I
filed another FOIA request asking for copies of those EPA "responses". Again, I got nothing.)
On November 5, 1997, I got a call from Linda Person of Washington, DC, EPA FOIA office. She told me Dr. Rubin
was "on edge" because I had filed my FOIA requests with EACH of the 10 EPA Regional offices. She said they
wanted to coordinate the reply from "headquarters" (Washington, DC) and that the regional offices are "panicking"
because they have "massive amounts of records."
I received little to no information about sludge complaints from EPA in response to those FOIA requests.
On November 19, 1998, Dr. Rubin testified before the N. H. House Environment and Agriculture Committee. In
response to questions from committee members as to possible adverse effects from landspreading sludge, Dr. Rubin
"We get reports that come in to us, either email, fax, written, phone calls, news reports, that claim there are impacts
on human health (and) the environment when biosolids are applied."
Ever optimistic, I filed another FOIA request on January 28, 1999, asking for copies of these "reports" claiming
impact on human health and the environment from sludge spreading, which were referred to by Dr. Rubin in his
November 1998 testimony to the NH E & A Committee.
Again, the EPA gave me nothing.
By letter dated February 2, 1999, Dr. Rubin referred to my prior FOIA requests and stated:
"I do not have any further information on alleged incidences in my file. However, US EPA is gathering information on
reported incidences of potential impacts from biosolids use/disposal projects. This activity is being coordinated and
managed by Robert Brobst, USEPA's Biosolids Coordinator Region 8. I suggest that you contact Mr. Brobst and
request either directly or through a FOIA mechanism the type of information that you are seeking in this FOIA
On November 25, 2000, I filed two more FOIA requests - one with Mr. Brobst, Region 8, Denver, and one with EPA
headquarters regarding EPA's testimony to House Science Committee in March 2000 about allegations of damage to
public health and the environment from sludge.
By letter dated January 23, 2001, Mr. Brobst stated: "Al Rubin of EPA headquarters was mistaken in stating that I
was responsible for tracking all biosolids incidents. I am not." Thus, Dr. Rubin was not telling the truth when he told
me Mr. Brobst was coordinating the sludge victims' information.
So we appear to have a shell game going. Just where are the EPA's sludge victims files?
I have been told by numerous sludge victims from around the country that they contacted the local EPA office asking
for help. Every one of them say the EPA ignored them. And none of the EPA Regional Office ever complied with
my FOIA requests by acknowledging contacts by those sludge victims.
In March 2000, the EPA told the House Science Committee it didn't have money or the inclination to enforce sludge
issues. "Biosolids is not a national compliance and enforcement priority."
But the EPA has given millions of our tax dollars to the WEF (Water Environment Federation -- whose members are
the sludge producers and sludge spreaders) .... to promote landspreading of sludge and to debunk and discredit
sludge victims and those who claim present policies do not protect human health or the environment. This booklet
just skims the surface. The truth about the harm being done to human health and the environment from the
landspreading of sewage sludge lies in the files EPA has been concealing from the press, public and Congress for
In June and July of 2002, EPA microbiologist David Lewis published the first peer reviewed articles in medical and
scientific journals documenting illnesses and deaths linked to sludge exposure. Yet the EPA and the waste industry
still claim that there are “no documented cases.” As long as the EPA continues to protect itself and the sludge
industry by withholding all records of sludge complaints and by ensuring that our tax dollars go only to sludge-friendly
researchers ( while independent scientists, like Lewis, are harassed and fired) land application of sludge will continue
to threaten rural America.
Helane Shields, Alton, NH