04/27/06

NEBRA Commentary on Caroline Snyder Critique of EPA in the International Journal of Occupational and Environmental Health

In November 2005, the International Journal of Occupational and Environmental Health (http://www.ijoeh.com) published a paper by Caroline Snyder, PhD, a New Hampshire citizen who has expressed concerns about biosolids recycling over much of the past decade. The paper appears with other papers in a "special issue" of the journal focused on "corporate corruption of science." Fluoride, genetically modified organisms, and leaded gasoline are subjects of other papers in this same issue.

The abstract of Dr. Snyder's paper states: "Serious illnesses, including deaths, and adverse environmental impacts have been linked to land application of sewage sludge. EPA and the wastewater treatment industry have worked with Congress to fund wastewater trade associations to promote land application, supporting industry-friendly scientists and discouraging independent research, to prevent local governments from restricting land application and to thwart litigation against municipalities and the industry." In making these charges, the paper ties together many disparate events and statements from a wide variety of public and private reports, court documents, letters, internet sites, media news stories, and a few formal published papers. Dr. Snyder's arguments build, in part, on those of Dr. David Lewis, a former EPA scientist who also criticized EPA's sewage sludge management regulations, policy, and the science behind them. Dr. Snyder's paper can be downloaded at: http://www.ijoeh.com/pfds/IJOEH_1104_Snyder.pdf .

NEBRA, one of the professional associations that Dr. Snyder's paper criticizes, understands and appreciates that the application to soils of treated sewage sludge/biosolids can sometimes be a contentious topic. However, thirty years of concerted research and experience with biosolids recycling have found "negligible risk," as a 1996 National Academy of Sciences review stated. A second National Academy review in 2002 found "There is no documented scientific evidence that the Part 503 rule has failed to protect public health. However, additional scientific work is needed to reduce persistent uncertainty about the potential for adverse human health effects from exposure to biosolids" (see http://www.nebiosolids.org/scienceof.html for more details). Indeed, the science behind current biosolids management policies and activities, as in other fields, is not static - current ongoing research addresses not only emerging issues of concern, but ways to improve existing biosolids use and management techniques

Dr. Snyder's paper reports no new research. Underpinning her arguments are rare incidents of alleged harm caused by biosolids - rare as compared to thousands of successful, beneficial biosolids recycling projects. The alleged incidents of harm were reviewed by independent authorities closer to the events in time and space. Those reviews reached conclusions different from those reached by Dr. Snyder's paper. In 2003, U. S. EPA refuted these allegations of harm, one by one, in a letter of response to a petition that Dr. Snyder and others submitted to the agency.

U. S. EPA, state agencies, public wastewater treatment facilities, professional organizations, and private companies involved in the management of sewage sludge are not infallible. However, the vast majority of people involved in the important environmental program of cleaning wastewater and managing sewage sludge are hard-working, fair, honest, and dedicated to protecting the environment and serving their communities. Improvements to programs are a good idea and will continue, including in areas of concern expressed by Dr. Snyder. However, even though, as Dr. Snyder notes, there have been many reviews and much scrutiny of EPA sewage sludge management policy (by the Inspector General, two National Academy panels, courts, and a Congressional subcommittee), none have reached the same conclusions as does Dr. Snyder, such as her statement "EPA's handling of the biosolids issue... illustrates what appears to be the complete corporate control of EPA's land-application policy."

An alternate conclusion is that Congress, most state and federal regulatory agencies, most public wastewater treatment facilities, many private company personnel, and many researchers agree with the National Academy review panels that recycling biosolids to soils, while worthy of continued scrutiny and ever-improving practices, presents negligible risk.