EPA, Others Misrepresented Health Risks Of Sewage Sludge

The terrorist attacks of 9/11 reminded Americans of the importance of defending the homeland from all threats–foreign and domestic. Unfortunately, American soil and our water have become hopelessly contaminated with deadly chemicals and neurotoxins. Laws, science and public health are being ignored as the bioterrorism persists today.

The U.S. government enacted the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (the Bioterrorism Act) to protect the homeland, including food and water supplies.

Despite these systems and safeguards, 99 percent of us now have highly toxic PFAS in our blood as part of the largest chemistry experiment in world history. Meanwhile, the mismanagement of infectious waste is fueling an unstoppable surge in neurodegenerative disease among humans and wildlife (and possibly livestock). Family farms and public health are being destroyed by bioterrorism.

Most Americans and others around the world are consuming PFAS-contaminated water and/or food, using contaminated products or breathing contaminated air. At least 45 percent of America’s tap water is estimated to have one or more types of the chemicals known as per- and polyfluorinated alkyl substances, or PFAS, according to a 2023 study by the U.S. Geological Survey.

There are more than 12,000 types of PFAS, not all of which can be detected with current tests; the USGS study tested for the presence of 32 types. PFAS is just the tip of a very large and very toxic iceberg. Unstoppable neurotoxins might pose an even more formidable threat.

Mismanagement Has Weaponized Sewage Sludge

Wastewater is the largest waste stream in the world and possibly the most toxic waste stream in the world. It is largely unregulated. Wastewater treatment facilities in the United States alone process approximately 34 billion gallons of wastewater every day. There was a time when human sewage was a fairly benign substance that cities and towns could disperse naturally without threatening an entire nation.

Today’s wastewater stream includes everything dumped down the drains and toilets at homes and offices, factories, hospitals, health clinics, slaughterhouses, mortuaries, auto repair shops and much more. It isn’t fertilizer.

We’re all part of the sewage problem, but misinformation, disinformation, incomplete science and more have compounded the problem at all levels. It has caused an environmental catastrophe and a public health disaster. It is still unfolding and gaining momentum.

Wastewater treatment plants are barely able to separate the liquids from the solids in this high-volume, toxic soup. Neutralizing and removing all neurotoxins, forever chemicals and radionuclides, for example, is impossible. Safe handling and disposal of this deadly waste stream is imperative, but the reality is much different. After superficial treatment, the water and the solids are pumped right back into the homeland for reuse. Just a few years ago, sewage sludge killed underwater ecosystems, when dumped at sea. Today, it is being hyped as fertilizer for farms, ranches, golf courses, parks, ballparks, school grounds, cemeteries, forests and beyond. Like magic, sewage sludge became biosolids and wastewater is now drinking water. The waste stream is the new gold rush. What could go wrong?

Sewage Sludge Kills Ecosystems

In October 1972, Congress enacted the Marine Protection, Research and Sanctuaries Act (MPRSA), a.k.a. the Ocean Dumping Act, to regulate the dumping of all materials that adversely affect human health, welfare or amenities, or the marine environment. It took the Ocean Dumping Ban Act of 1988 (an amendment to the MPRSA) to prohibit the dumping of municipal sewage sludge, industrial waste and medical waste into the ocean.

Bans were motivated by the discovery of contaminated wastes from sewage-derived microorganisms at public beaches, toxic metals in shellfish beds, and parasites in fish. Sludge can contain heavy metals like cadmium and copper, which sewage treatment plants can’t filter out. Ocean dumping can destroy marine habitats and ecosystems.

Unfortunately, the U.S. Environmental Protection Agency (EPA) has been pushing a different story for the past 30 years. In response to the ban on dumping sewage sludge at sea, the EPA expedited a flawed, if not fraudulent, risk assessment and concluded that the toxic waste that destroyed marine ecosystems was actually beneficial to open land, including farmland, ranches, forests, parks, golf courses, school grounds, ballparks and city parks.

Biosolids is a glorified term for sewage sludge. The EPA estimates that more than 2.4 million tons are applied to land annually as fertilizer on farms, pastures, parks, home gardens, and other lands. Biosolids are made from both municipal and industrial waste, and although they are treated to remove pathogens and some other materials, PFAS are not removed during treatment and EPA does not currently limit the amount of PFAS they can contain.

It calls biosolids a cheap fertilizer (they pay farmers to take this toxic waste off their hands). Now, many farms and ranches are paying the ultimate price for this cheap fertilizer.

When applied to land, the toxins in sewage sludge ultimately make it into surface water runoff and groundwater. These solids bake in the sun and are reduced to particles that go airborne. When applied to land, sewage sludge contaminates everything downstream, including our food and water supplies. Plants uptake everything in the soil and water. The extreme weather associated with climate change is spreading this toxic waste far and wide.

When biosolids are applied to soil, they are used mostly for corn for animal feed and energy, followed by hay/grass/forage. Other popular crops for biosolids fertilization are wheat and other grains, followed by Class A EQ products widely used on turfgrass (lawns, erosion control, golf courses, landscaping).

The Sludge Rule

The US EPA regulates biosolids through the “503 Rule” (40 CFR Part 503 Biosolids Rule), which is affectionately known among critics as the sludge rule. The sludge rule is pseudoscience at best. It basically sweeps all risks and unknowns under the rug. It also holds those who manage and mismanage sewage sludge harmless against crimes against nature and crimes against humanity. For example, biosolids are classified into Class A and Class B, with Class A having stricter guidelines and no detectable levels of pathogens. Class A biosolids can be used in public areas, while Class B has restrictions on access and harvests from these contaminated lands. Let’s test those Class A biosolids for PFAS and neurotoxins.

EPA Admits Risk Assessment For Sewage Sludge Is Flawed

After falsely promoting the virtues of dumping sewage sludge on land for more than 30 years, the U.S. EPA admitted the error of its ways. In 2018, it announced that the risk assessment that it has relied on is actually incomplete. It failed to address all of the known contaminants and the emerging contaminants. It basically admitted that it authorized an illegal and reckless dumping program that has contaminated food, water, air and more. Unfortunately, the EPA failed to stop the practice of dumping sewage sludge on land–public and private. As a result, this illegal dumping program continues to threaten humans, livestock and wildlife.

PFAS are a large group of manufactured chemicals that are used to make everyday products, including cosmetics, carpet, food packaging, Teflon and fire retardants. PFAS are used in aerospace, automotive, construction, electronics, and military. PFAS is often listed on products as PTFE (polytetrafluoroethylene), perfluorooctyl triethoxysilane, perfluorononyl dimethicone, perfluorodecalin, and perfluorohexane.

The medical world is still analyzing the full impact of PFAS on human and animal health, but we know that sewage sludge is soaked in these forever chemicals and that biosolids are contaminating food, water and families today. Forever chemicals can increase the risk of many diseases and disorders:

Decreased fertility, increased risk of high blood pressure in pregnant women, and lower infant birth weight;
Accelerated puberty, bone variations, or behavioral changes in children;
Decreased response to vaccines in infants and children;
Higher cholesterol and elevated liver enzymes;
Increased risk of some cancers, including kidney, testicular, and prostate cancers; and
Increased risk of thyroid disease, with sex-specific outcomes in women and men.

Unfortunately, the companies who developed and manufactured PFAS knew about many of the dangers associated with this new class of compounds all along. Thanks to negligence and fraud, the vast majority of Americans of all ages are now part of this chemistry experiment. It’s safe to say that PFAS has contaminated most of the food and water supplies around the world. The contaminant also threatens fish, wildlife and livestock.

PFAS + Pathways = Victims

Since PFAS chemicals are found in so many different products, assessing the potential human health and environmental risks are extremely complex. Risks are associated with manufacturing, distribution, usage and disposal.

Thanks to one very tenacious lawyer named Robert Bilott, legal battles against PFAS are gaining momentum. The movie Dark Waters summarizes Bilott’s courageous work and it documents the horrors of Dupont’s deceit. The movie is based on an article written by Nathaniel Rich, a reporter for the New York Times. Bilott is an environmental attorney from Cincinnati. He is known for PFAS lawsuits against DuPont on behalf of plaintiffs from West Virginia. Mr. Bilott has spent more than twenty years litigating hazardous dumping of forever chemicals.

Thanks to Bilott’s groundbreaking work, San Diego is suing more than 20 companies over water contamination caused by PFAS. The lawsuit claims that 3M, DuPont, Raytheon and others made firefighting foam that contained PFAS and alleges the companies were aware of the toxic nature of the chemicals, but concealed the environmental and public health dangers.

Neurodegenerative Disease Soaring Among Mammals

Unfortunately, PFAS is only part of the toxic threat posed by dumping millions of tons of sewage sludge (biosolids) on land. Neurodegenerative disease is now the fastest-growing cause of death in the world. Most of this surge is caused by a neurotoxin called a prion. Thanks to misinformation, disinformation and overall mismanagement, this unstoppable neurotoxin is spreading through our food, water, health systems and beyond.

Prions are a formidable threat. The government initially classified prions as select agents, which means that they pose an extreme risk to food, water and health systems. Since prions don’t usually kill within days of exposure, they were removed from the list. Neurodegenerative disease has been surging around the world for the past 30 years and prion contamination is driving this silent, but massive pandemic.

Prion disease includes Alzheimer’s disease, amyotrophic lateral sclerosis (ALS), Creutzfeldt-Jakob disease (CJD), chronic traumatic encephalopathy (CTE), Gerstmann-Straussler-Scheinker disease (GSS), Huntington’s disease, Parkinson’s disease and others. Many of these diseases are related in terms of cause and pathology. The biggest difference between the different prion diseases is the region of the brain that’s under attack. The scientific name for prion disease is transmissible spongiform encephalopathy (TSE). As the name implies, all forms of TSE are transmissible. They are impossible to stop.

Since deadly prions spread through the bodily fluids and tissue of those carrying prion disease (milk, blood, saliva, mucus, urine, feces, tissue and skin), that’s a problem for wastewater systems. Prions shed from infected humans are highly transmissible.

Prion disease also is known as mad cow disease in livestock and chronic wasting disease in wildlife. The only difference between these diseases is the species impacted. There is no such thing as a mad cow prion or a CWD prion. An infectious prion is a deadly prion that can jump species barriers with ease. Prions migrate, mutate and multiply. There are now millions of mutations. Cattlemen in America claim that there is no need to test their livestock for mad cow disease. As long as some livestock are deliberately exposed to prion contamination in biosolids, food safety is a legitimate concern. If we don’t stop dumping sewage on land we must start testing for prion disease, which will cost even more than doing the right thing with toxic waste.

The U.S. Environmental Protection Agency (EPA) has confirmed that prions are in sewage sludge and wastewater–and that there is no way to detect them or stop them. As such, the EPA has never issued guidance on prion management within sewage processing plants. This lack of directive allows budget-strapped states and counties to regulate the practices in a variety of ways that best suit local municipalities and industries.

After years of mismanagement, wastewater treatment plants have become prion incubators and distributors. When released on open land, the prions shed from humans will find more victims. Prions shed from humans are typically the most aggressive because prions mutate as they move up the food chain.

Prions + Pathways = Victims

Managing prion pathways, and preventing new ones, is clearly part of the equation. Reusing components of this waste stream is causing a public health catastrophe. Victims and stakeholders are pushing back. Rightly so. Safer alternatives exist.

According to prion researcher Joel Pedersen at the University of Wisconsin, prions in soil become up to 680 times more infectious. From there, they migrate, mutate and multiply. It’s a real world version of Pandora’s Lunchbox.

“Our results suggest that if prions enter municipal wastewater treatment systems, most prions would bond to sewage sludge, survive anaerobic digestion, and be present in treated biosolids,” Pedersen said. “Land application of biosolids containing prions represents a route for their introduction into the environment. I emphasize the importance of keeping prions out of municipal wastewater treatment systems.”

Prions could end up in sewage treatment plants via slaughterhouses, hospitals, dental offices and mortuaries just to name a few of the pathways. The disposal of sludge represents the greatest risk of spreading prion contamination in the environment. Pedersen also found that sewage treatment does not inactivate prions. Therefore, prions are lethal, mutating, migrating and multiplying everywhere sewage (biosolids) is dumped.

Prions in humans have worked their way up the food chain, so prions shed from humans are typically much more aggressive and they don’t respect species barriers. Prions in sewage and other forms of infectious waste are driving the explosive growth in neurodegenerative disease among our friends and family members. The incidence of Alzheimer’s disease, Parkinson’s disease, Creutzfeldt-Jakob disease, ALS, and other forms of neurodegenerative disease have never been higher. Neurodegenerative disease is the fastest-growing cause of death in the world. There is no vaccine and no cure. Prevention is the only defense.

Prions shed from humans in municipal sewage sludge have caused much of the explosive growth in chronic wasting disease–in the wild and on deer farms. This prion super-highway puts livestock at risk of mad cow disease. Crops grown in sludge also can uptake and transmit deadly prions.

How has such a dangerous dumping program escaped laws, including the Clean Water Act and the Bioterrorism Act? Like forever chemicals, prion contamination lasts forever.

How Much Sewage Is Dumped On Land In Your State? The Environmental Working Group estimates that 5 percent of the nation’s cropland, or 20 million acres, could be using sewage sludge as fertilizer. Unfortunately, it is being dumped on open land of all types, including ranches, golf courses, parks and school grounds. Follow this link to see how much sewage is reclaimed and dumped in your state. https://www.biosolidsdata.org/

Safer Alternatives Available. Surveys of Wastewater Reclamation and Reuse Facilities show that the average costs to have a contractor take and manage solids from wastewater treatment plants is approximately:

$49 per wet ton for composting;
$58 for landfill disposal;
$62 for land application; and
more than $95 for incineration.

It’s cheaper to landfill this toxic crap than to dump it in our watersheds and in our communities. Most state regulators have few resources dedicated to biosolids oversight.

Nations, States and Communities Banning Biosolids On Land

There are no labeling or disclosure requirements for food grown in sewage sludge. However, some companies, such as Heinz and Del Monte, prohibit the use of sewage sludge as a fertilizer for their products. Fortunately, most nations, states and counties are waking up to the consequences of bad public policy:

In 1995, the Netherlands banned the spreading of sludge on its own farmland, but later began exporting it to other countries.

In 2000, the U.S. Department of Agriculture finally ruled that food grown in sewage sludge can not be classified as organic. Only by purchasing food with the certified organic seal can you be sure that your food was not grown in sewage sludge.

In 2003, Switzerland banned the use of sludge due to concerns that sludge contains harmful substances and pathogenic organisms that could damage soil, harm public health, and negatively impact food quality.

In 2004, the Superior Court of Richmond County, GA dismissed claims filed by McElmurray Farm that land-applied biosolids caused the deaths of dairy cows in the 1990s. In 2008, a federal judge ordered the Agriculture Department to compensate McElmurray whose land was poisoned by sludge from the waste treatment plant here. His cows died by the hundreds. The judge ordered the government to compensate dairy McElmurray because 1,730 acres were poisoned. The sludge contained levels of arsenic, toxic heavy metals and PCBs two to 2,500 times federal health standards. The level of thallium — an element once used as rat poison — found in the milk was 120 times the concentration allowed in drinking water by the Environmental Protection Agency.

In 2014, health foods grocer Whole Foods stopped sourcing produce from growers who use sewage sludge on their farms.

In 2022, in response to PFAS contamination, Maine became the first state in the nation to end the beneficial use (land application) of wastewater biosolids, which created a series of challenges for Maine’s wastewater systems and produced landfill capacity problems. Several farms have been shut down due to PFAS contamination. Rep. Chellie Pingree, D-Maine, and Agriculture Secretary Tom Vilsack have met with the farmers in her state who have found PFAS contamination. High levels of PFAS have shut down dairies, and at least some organic vegetable farmers have voluntarily stopped selling produce after water levels showed high concentrations of PFAS chemicals.

“We are finding it all over our state,” Pingree said. “Some of the farmers don’t have the time to wait for the state, so they are paying for their own testing. They are finding extremely high levels of contamination in their bodies and in their children’s bodies. I just can’t say enough how hard it is to witness what is going on.”

Pingree credited Maine lawmakers for agreeing this year to spend $100 million to help farmers whose ground has been contaminated. Decades of using sewage sludge as a fertilizer has ruined farms, Pingree said.

Maine’s crackdown began in 2017, when Fred and Laura Stone had to shut down their dairy farm due to extreme levels of PFAS contamination caused by spreading sludge on their farm decades ago. Maine has since created a $60 million fund to help PFAS-impacted farmers.

In 2022, Michigan seized Jason Grostic’s farm and banned the sale of milk or meat because of PFAS contamination. States such as Michigan have been finding high volumes of PFAS chemicals in city water and wells. But along with that, PFAS chemicals attach themselves to biosolids such as sewage sludge, which is how farmers in a few states are learning that their soils are contaminated. Michigan set a standard of not allowing PFAS for land applications containing more than 150 parts per billion, and biosolids such as sewage sludge must be tested before it can be applied on land. Grostic, who lost his livelihood and property value, said other farmers need to understand what can happen with PFAS and sewage sludge.

In 2022, officials in Maine and Michigan each released warnings against eating fish from several streams, rivers and lakes because of high levels of PFAS/PFOS.

In New Mexico, in 2022, four years after milk from his dairy cattle tested positive for high levels of PFOS, Art Schaap finally euthanized the last of his 4,000-head dairy herd. Schaap learned in October 2018 that his dairy farm had been contaminated through groundwater just outside Cannon Air Force Base, where PFOS-laden foam chemicals were used extensively to train firefighters. Schaap’s dairy was prevented from selling both milk and cattle. The cattle were moved to clean water in February 2020. USDA officials wanted to see if the cows would shed the PFOS from their bodies once the cows were given clean water. But tests never showed any signs of improvement. Schaap, along with some dairies in Maine, received indemnity payments from USDA for dumping their milk.

Courtney Briggs, the senior director of government affairs at the American Farm Bureau Federation, said PFAS contamination is an emerging and alarming issue for its members.

“It sets off alarm bells and starts to create anxiety when you have a situation where, unbeknownst to you and through no fault of your own, your land could be contaminated by a forever chemical,” Briggs said.

In Texas, five farmers are suing Synagro for providing sewage sludge to a neighboring farmer who spread it on his land. The plaintiffs claim that the sewage sludge contaminated their water supply, affected their health, damaged their land and killed their livestock.

Dana Ames, an environmental crimes investigator with the Johnson County Constable’s Office, collaborated with Public Employees for Environmental Responsibility (PEER) to test the farmers’ water, soil, wildlife and livestock. Results found high levels of PFAS in well water, surface water, soil, fish and a stillborn calf. Ames also obtained a sample of Synagro’s fertilizer and had it tested. Many of the PFAS found in the sample were also present on the farms.

“The results we got back are very damning,” said Ames, who is pursuing a criminal case on the matter.

Ames predicts more lawsuits as more people nationwide test for contaminants from sludge. The lawsuit claims Synagro should have known the risks of the product and failed to warn users.

In 2024, the biggest water district in Maine is suing manufacturers of so-called forever chemicals in the hopes of recouping costs of monitoring and treating polluted wastewater. The Portland Water District lawsuit comes as the cost of the disposal of PFAS-contaminated sewage sludge has doubled from $1.6 million to $3.2 million over the last three years, and Portland has agreed to develop a regional biosolids treatment facility proposal with cost estimates ranging from $150 million to $250 million. The Portland Water District lawsuit focuses on wastewater. The district is already in compliance with strict EPA limits on certain PFAS in drinking water that will require utilities to reduce them to the lowest level possible.

Wastewater As Drinking Water

Unfortunately, the same regulators who sold us on the virtues of sewage sludge based on a fraudulent risk assessment also have sold us on the virtues of turning sewage into drinking water. Are those risk assessments “incomplete?” For example, how are they accounting for deadly prions? How do they establish a safe level for PFAS? Where is the data?

In Summary:

Dumping sewage sludge on land in the U.S. and other countries has always been illegal because there has never been a comprehensive, credible risk assessment that proves that dumping a toxic soup of neurotoxins, carcinogens, radionuclides, endocrine disruptors and PFAS on farms, ranches, golf courses, school grounds, ball parks, city parks, gardens and forests is safe;
The EPA should have immediately stopped all dumping of sewage sludge on land in November 2018, when it announced that its risk assessment is incomplete. It should be stopped immediately;
The states and counties should immediately disclose where sewage sludge has been dumped since the inception of the program. The property owners, their families and their neighbors should be notified about the past and present risks and independent health studies should begin immediately. Test all local water sources for contaminants. Remediate and contain the damage;
The US EPA should notify every nation that relied on its fraudulent risk assessment regarding sewage dumping. Canada, for example, just copied the one from the United States and called it a day. Since then, it had its first confirmed case of mad cow disease and it has given up on the fight against chronic wasting disease;
Make it mandatory to notify all land buyers, banks and insurers about the toxic history of sewage dumped on the properties that they underwrite or finance;
Compensate stakeholders for loss of property, injury and wrongful death;
Enforce the Bioterrorism Preparedness and Response Act of 2002, the Clean Water Act and other regulations designed to defend the homeland and more than 300 million Americans;
Review the risk assessment for reclaimed water that is being reused as drinking water and to replenish aquifers. How are they removing all PFAS and prions? and
Reform the EPA immediately to protect citizens and our vital natural resources. Several former EPA Administrators are leading that request.
Tell the truth about the prion pandemic. There is not a vaccine that prevents it. There isn’t a cure. It is always fatal. All forms are transmissible. There is no credible, scientific research that states otherwise. Misinformation, disinformation and wishful thinking are reckless. Yes, Alzheimer’s disease and Parkinson’s disease spread through bodily fluids, including blood and mucus. They spread through cell tissue, including skin. A mortician will not touch the body of someone who died of prion disease. Family, friends and caregivers beware.