NOTE: received by Email from Helane Shields on February 19, 2001
Hi folks .....your emails are URGENTLY NEEDED to smartel@nas.edu------
WITH COPIES TO DR. THOMAS BURKE, CHAIRMAN OF THE NEW COMMITTEE:
tburke@jhsph.edu
PROTESTING THE BIAS OF THE PRESENT COMMITTEE, MEMBERS' LINKS TO THE
WATER ENVIRONMENT FEDERATION, US EPA, WASTE INDUSTRY, HAZARDOUS WASTE
PROCESSING AND DISPOSAL (much still goes into public sewers/sludge
which provides for cheap disposal and transfer of liability)
Your email need not be long ... just a few lines to let them know we are
aware of the conflicts of interest and lack of objectivity of a majority
of the present provisional committee members.
HERE are 3 letters on the subject sent to NAS by fellow activists:
Dear Ms. Martel; I am sure that you must realize that biosolids
application is a topic of intense scrutiny all over the world, not just
the
United States. I am sure that you are aware of the Swedish position,
for
example. That is why I am concerned about the composition of the people
on
the study committee. Because of all the issues with acceptance of
biosolids, it would seem to be more prudent to have a balanced
committee.
I have researched the proposed members and I feel that it will be
difficult
for their conclusions to be taken seriously. If you truly want the
results
to be considered credible, I would convene a different composition of
individuals on that committee. Thank you.
*************************************************************************************
Susan Martel, Project Director
National Academy of Sciences
2101 Constitution Avenue
Washington, DC 20418
February 16, 2001
Dear Susan Martel,
As a resident of New Hampshire and an advocate of policies which protect
health and the environment, I appreciate the opportunity to comment on
the proposed appointments to the NAS/NRC committee to review EPA sludge
policies.
New Hampshire residents are particularly concerned about the 503s, since
we have seen, first-hand, the results of EPA regulations which have not
been protective of health and the environment.
The town in which I live has, for years, been the repository for sludge
highly contaminated by the very industries which have, and will continue
to define sludge policy should the NAS/NRC formalize the appointments as
currently listed.
To have a committee which is truly balanced, there would need to be one
individual--unaffiliated with industry and the EPA--appointed for every
member who represents an industry dependent on the wastewater industry
and on EPA regulations which place the need for cost-effective solutions
to waste management above the need to minimize risks to health and the
environment.
In reviewing the proposed membership, I have not been able to find a
single individual whose sole reason for involvement would be protection
of the environment and health. If the purpose of this committee is to
address the safety of land-application of sludge, clearly the
composition of the committee as proposed raises serious questions.
The question which emerges first and foremost is: What is the true
intent of the committee if most members have a pecuniary interest in the
policy? It is not difficult to see that most individuals listed have an
interest in keeping the 503 regulations weak, since the companies that
they represent would incur greater costs should the 503s need to be
strengthened to protect human health and the environment.
All over the country we have seen individuals, indeed entire
neighborhoods, sickened as a result of sludge rules that do not address
questions and problems that continually emerge, while the EPA continues
to defend the existing sludge policies. Serious questions remain
unanswered also in regard to sludge-related deaths and in regard to the
reproductive and carcinogenic effects of the toxins in sludge.
It is unconscionable that the NAS would launch a study of health effects
of sludge by a committee comprised of representatives of industries
whose profits depend on cost-effective solutions to waste disposal.
It is essential to include researchers whose work is not funded by the
WEF , the chemical industry, and other industries handling and disposing
toxic wastes.
It is essential to include researchers who would not conclude that
sludge is safe because it does not pose any risk to residents 6 miles
from a sludge site while ignoring their own documentation of high risk
to residents who live from 0-1000 feet from the site. I am referring to
the work of Dr. Ian Pepper on bioaeresols in sludge and the related
appointments of Ian Pepper and Suresh Pillai which clearly represent the
status quo of sludge policy.
It is essential to include representatives of individuals who have
suffered as a result of EPA sludge policies, individuals who the EPA
maintains do not exist--while claiming it would cost $40,000 to provide
copies of the EPA files on claims of harm caused by sludge.
It is essential to include representatives of researchers at the
Cornell Waste Management Institute who have conducted extensive,
independent research on the toxins and pathogens in sludge.
It is essential to include representatives of groups working in the
interest of human health and the environment.
It is essential to have an appointee who is capable of addressing the
proposed 300 ppt limit for dioxins and the question of contamination of
milk and milk products by these substances and their connection to the
high rates of breast cancer and reproductive disorders. This is of
particular concern in a state like New Hampshire where the major
dairy—Crowley Foods—gets its milk from sludged farms. For most of the
population, Crowley is the only source of locally produced milk and
distributes milk to thousands of school children statewide.
In bringing my concerns to the leadership of the NRC, you will have the
opportunity to personally advocate for a true balance within this
committee. Please let me know if you intend to advocate for the changes
that are necessary in the committee appointments in order to conduct an
objective study.
Sincerely,
*********************************************************************
To: Susan Martel
From: Caroline Snyder, Ph.D. Citizens for a Future New Hampshire( CFNH)
Re: Formal Comments on the Provisional Appointments to the NAS
Committee that will consider Toxicants and Pathogens in Biosolids
Fertilizer.
February 13, 2001
Thank you for the opportunity to submit formal comments on the
provisional appointments to the committee that will study some of the
health effects of municipal sewage sludge that is land applied. CFNH
has a number of serious concerns about the make-up of this committee.
It appears that this committee is not balanced and therefore will not
be able to fulfill its task in an objective manner. Most of the
proposed committee members have strong ties to the EPA, to the Water
Environment Federation, to waste water treatment facilities, and to
hazardous waste management industries. All of the above mentioned
groups or agencies are openly or implicitly promoting Class B land
application under the current rules. Even the title of the proposed
report reflects bias: ‘biosolids’ is a public relations term that has
no regulatory status. A more accurate term for the material under
consideration is ‘municipal sewage sludge.’ Also, the Clean Water Act
defines sewage sludge as a pollutant, not as a fertilizer. A more
objective title for this project would be: Risks from Toxicants and
Pathogens in Sewage Sludge that is used as Fertilizer.
We are also concerned that many members of this committee appear to
believe that mathematical modeling and risk assessment is the primary
tool for policy making. Although risk assessment can be useful, it is
increasingly perceived as an unreliable tool for protecting the public
from hazards, especially from health hazards contained in such an
unpredictable, unknown, and biologically active mixture as Class B
sludge.
We are especially concerned that this committee does not include
independent scientists and private citizens who have voiced legitimate
reservations about the safety of land application. For many years ,
and especially in the last year, EPA’s Office of Water has been accused
of stifling the debate on whether or not the 503s are protective of
human health and the environment. In fact, on March 22, 2000, the US
House Science Committee held a hearing with the title: EPA’s Sludge
Rule: Closed Minds or Open Debate. One of the purposes of this hearing
was to address “whether EPA is failing to foster sound science with an
open exchange of ideas and information between scientists, EPA
officials, and private citizens.”
Surely this forthcoming NAS/NRC study on the safety of land application
should be based on “an open exchange of ideas.” Such an open exchange
will not occur if most of the panel members accept or support the
current sludge rules. Such an exchange of ideas can only take place if
some of the key players who have been active in the sludge debate are
included on this committee.
Finally, CFNH is concerned that this NRC project will be too narrowly
focused. It does not address the impact of land application on the
environment. Nor does it address the acknowledged long-term adverse
effects of repeated land application on the nation’s farm land. Perhaps
this is not a primary concern in some of the mid western states
where in-state sludge can be land applied by using less than 1% of
crop land. However in New Hampshire, over 20% of the state’s
agricultural land would have to be used, if all of the in-state sludge
were land-applied. CFNH believes it is not acceptable to permanently
degrade such a large percentage of New Hampshire farm land. Perhaps
these two issues can be addressed in future NRC projects.
Meanwhile, our primary concern is the unbalanced make-up of this
committee. In a democratic society, good public policy must be based on
honest and open debate. Such a debate will not occur during the
deliberation of this committee, unless you include citizens and
scientists who are currently key players in the sludge debate.
Sincerely yours,
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