More On Sludge, "The Whole Nine Yards"

Look closely at the Baltimore Orgro Lead Contamination Study:

"Biosolids compost amendment for reducing soil lead hazards: a pilot study
of Orgro amendment and grass seeding in urban yards"
by Farfel, Orlova, Chaney, Lees, Rohde, Ashley

Intro - Why is lead contamination allowed to continue in poor communities?

Many of us have been deeply shocked that in the USA rental residences that
have lead contaminated yards are not remediated....whether by order to the
owner, or at state expense. It is shocking that children living in these
housing units continue to be exposed to lead contaminated properties and
suffer neurological damage as a result.

What do they do with contaminated properties in Ontario Canada?

I recently asked Ontario officials what would happen if such contamination
were found in this jurisdiction.

I was told that this would be considered environmental pollution so as to
cause an 'adverse effect' and that when the provincial gov't became aware of
the problem they would order the property owner to remediate the problem.
If the contamination was linked to an offsite industrial source, then the
owner of the pollution source might receive an order to clean up the
properties.

The owners would likely hire consultants to come up with a remediation
strategy which the Ministry of the Environment would review, or the Ministry
experts would order a clean up..specifying how it would be done and when it
would be completed.

The site would be tested...and if say..the surface of the soil was the most
contaminated, they would remove the soil with the highest concentration if
lead very carefully..so as not to release it as dust during the clean up.
Then they would remediate the rest in such a way to minimize the amount of
fugitive dust, and in a way that would keep the lead away from being
dispersed.

So why doesn't this happen in the USA?

Let us compare this with what happened in Baltimore

In Baltimore the suggestion is that there was no lead remediation because
there is no industrial source responsible for the lead. Is anyone really
clear where the lead came from? I hear lead paint on the exterior of the
buildings, and maybe a now closed smelter in the neighborhood. (NOTE: Homes
near streets have soil contaminated by the lead in gasoline emissions. Lead
was removed from gasoline after a ground breaking 1979 study by Dr. Herbert
Needleman and the micrograms of blood lead levels was reduced from 40 mc to
10mc per d/L at the CDC. I am sending you an article from Discover Magazine
which talks about this AND check out the links to Dr. Needleman and how
industry tried to ruin him. I expect lead contaminates soil near busy
streets in all cities.)

So if it is from the homes, why are the owners not obligated to do the
cleanup?

Looking further at the Baltimore Farfel, Chaney, et al study. Remember now
that they spent $464,231 ...nearly half a million dollars on this project.

Did they remove any contaminated soil? No

Did they contain the contaminated soil? No

Did they take steps to be sure not to get dust into the air?
No - just the opposite.
They rototilled it - twice

Did they expose families and children to dust during the yard remediation? -
YES

First- by rototilling the lead contaminated soil twice

Second - Did they seek to make sure that the bare soil (some of it 5 or 6
times the EPA maximum for children's play area) was covered..so families
were protected from lead dust ? NO - indeed they took off all the plants
that were holding down the soil, rototilled the contaminated soil into fine
dirt, and then LEFT THE SOIL BARE. Instead of putting down sod to hold down
the contaminated dirt (contaminated with lead and whatever was in the
sludge) they just put grass seed on. (Did the study show pictures of straw
spread over the grass seeds?)

Third - They did not rope off or fence the now bare soil yards. There was
nothing to stop people from walking across the bare soil, crushing the
seeded soils, and tracking the lead and sludge contaminated soil into homes
and cars and tracking it into dust to blow around the neighborhood.
IMPORTANT NOTE: Since Cheney and Farfel believed the sludge was safe, what
made them think that the lead had been de-activated and no longer a human
health danger?

So what they did left this community MORE exposed to lead than before during
the course of the experiment. And even though they said the purpose was to
see if they could reduce the exposure of the residents to lead, they never
used ANY indicators to see if the experiment actually resulted in lower
exposure to lead.

Did they maintain the yards? No....only one yard was maintained by the
researchers. The residents were somehow supposed to maintain the seeded
yards.

Did they provide the residents with the means to maintain the new growth on
the lead contaminated sludge spread properties? No
Did they provide sprinklers and hoses? Lawn mowers? Push rotary mowers?

No. In fact the authors say a follow up study is needed to "assess the
ability of residents to maintain a grass cover". see page 93

Is there any evidence that the grass grew in these bare soil yards seeded
with grass - No.
There is only one photo of grass growing in a yard - which was likely the
one yard the researchers watered and maintained

So the researchers - claiming that the poor black kids would now ingest soil
that was mixed with sludge argued that eating the sludge amending lead
contaminated soil would result in lower lead levels in the children's' blood.
Not only did they not take steps to stop fugitive lead contaminated dust -
they argued that ingesting the sludge amended dust would be 'healthful'.

But they didn't check the children's' blood - neither before nor after the
experiment. They did not check for lead, they did not check for sludge
related diseases or conditions either.

Many questions are unanswered. Why did they not disclose the levels of all
the Part 503 and Maryland state sludge compost requirements? Why did they
fail to provide the required test results on selenium, molybdenum, mercury,
and PCBs? Why is there no data on the pathogens in the sludge compost? And
why were the residents not told that sewage sludge compost would be brought
to their homes?

The researchers declared the experiment a success - because they said that
the bioavailability of the lead in the amended soil was lower in the final
soil than in the unamended boxed soil samples.

Certainly some of the lowering of the lead levels was due to the dilution
effect. But - had they put far more lead dust into the community and the
community homes by their actions? As a result of stripping off the grass
cover and tilling up the lead contaminated yards and leaving them in a bare
and friable state have they dramatically increased the lead ingested by the
families and children? They never checked. Did the contaminants including
metals, neurotoxins, and pathogens in the sludge result in illness? They
didn’t check.

The researchers claim, in the study, that the original condition of the
yards - with a few bare patches of hard packed lead contaminated earth - was
a risk to the community from windblown dirt. So what did they do? They
took off all the plants that were holding down the contaminated soil,
rototilled it up twice to make it loose and friable, and then left it like
that - to blow around the lead contamination on a wholesale basis.

And of course, did the families - already weakened from lead exposure -
suffer other health problems because their immune impaired bodies now had to
deal with arsenic, mercury, and other toxins and endotoxic pathogens in the
sludged soil?

We don't know. They didn't do any health checkups. Not for lead. Not for
anything.

While explaining that they were looking for a cheap way for lead
contaminated residents to do a 'home fixer upper lead hazmat remediation'
these researchers arguably endangered these families.

Was there even one yard that was kept as a ‘control field’?

No

The researchers put some dirt from the yards in a container and kept it for
a year.

Even this dirt showed an 8% reduction in lead bioavailability.
If they really wanted to show that their treatment made a difference they
should have used one yard as a control. Maybe they did, and then just wrote
it out of the study?

Could any reviewer think it is not extraordinary to have an experimental
design that involves waiting a year, scraping off the top layer of soil, and
representing the results as an accurate representation of the soil
representing community exposure? But the journal “Science of the Total
Environment” refuses to say who peer reviewed this paper.

Project designed to achieve skewed results.

Here is a curious fact. When they did the first tests on the yards they
measured the dirt in the yards 'as is'. When they went back one year later
they scraped off the top - most contaminated - layer of soil off the
sampling site and THEN took their sample. Voila - lower levels of lead.


The project design on page 83 states:

“Thus, the composted biosolids amendment approach has the potential to
reduce risk from Pb in urban soils by
- reducing direct contact with bare soil
- -transfer of soil into the house and
- The bioavailability of Pb in ingested soil”

But we see that what the researchers did to the soil in the yards INCREASED
direct contact with bare soil, and was likely to INCREASE transfer of soil
into the house.

So lets look at Lead (Pb) bioavailability

Was there a genuine drop in lead bioavailability?
Hard to say. There is an intriguing note on page 93 that states that there
may be a drop in in bioaccessible lead “as a result of an artifact of
bioaccessibility testing in that the chemical reactions to make pyromorphite
occur during the extraction as well as in the field.”

So was the bioassessibility data in any way meaningful? Was the
bioassessibility only an artifact of the test methods they used?
Were there weeds at the test location ? In fact if there was clover growing
on some yards, the clover could have done a phytoextraction of the lead in
the soil samples.

And why are there suddenly only 8 yards under study? What happened to the
9th yard? Why is there no yard by yard data? Why is the data all averaged?

Dust studies

The big issue for community exposure was said to be the dust that could blow
into homes. So why is there no detailed analysis of this dust provided in
the study? Why are we told that dust followup studies are needed?
WHY IS THE DUST ON THE TOP OF THE FINAL SOIL TESTS REMOVED BEFORE THEY DO
THE ONE YEAR FOLLOW UP?

If the top layer of soil is such an important reflection of community
exposure, why is this layer removed in the experimental design, before
arriving at the soil test results at the one year followup mark? This
project was designed to advertise sludge as providing a method for lead
remediation, when in reality the testing by design was deliberately skewed
and fudged to provide misleading results.

Where is the community participation?

They claim they did this study with the participation of community
organizations?
Where is their input? Where are their comments on the study?
The researchers claim they sent the participants copies of the lead tests on
their yards. Why is this data not included in the study?

Were Occupational Health and Safety requirements met?

My understanding is that remediating a lead contaminated site requires
workers with respirators and hazmat training. These residents don't have the
equipment or training to do soil remediation. This is a preposterous
suggestion.

What about the money?

What the researchers do want is to find a way to get rid of all the sludge
compost. Interesting that the Orgro webpages say the sludge compost is
available for $3 - $9 per yard.
(http://wasteage.com/mag/waste_composting_baltimore_city)

But the Farfel paper says it is worth $30 per yard.

Did USFilter get a charitable receipt for their 'donation' of Orgro? Did
they inflate the value fraudulently to get a tax receipt for their
'charitable donation'?

And where did all that grant money go? The researchers brag that they did
this 'clean up' for only $150 - $350 per yard. Lets see...that is less
than $4000 for the whole nine yards.

Grant money of $446, 231 minus $4,000 which includes the $10 in food
coupons they gave each household as an inducement to participate and ...
lets see....
So what did they do with the other $442,231?

Where do we go from here?

WE need an audit of this experiment.
A science audit.
A toxicology audit.
An occupational health and safety audit.
A financial audit.
A granting projects audit.
An ethics audit.
We need an inquiry into what kind of research is being undertaken at the
expense of these lives.


Maureen Reilly
Sludge Watch
April 27, 2008