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From : 
"hshields" <hshields@worldpath.net>
To :  "Jane Wingate" <wingate@worldpath.net>, "CHARLOTTE HARTMAN, NATIONAL SLUDGE ALLIANCE" <chartmannsa@taconic.net>, "CHARLIE REID" <charliereid@ttlc.net>, "CAROLINE SNYDER" <cgsnyder@post.harvard.edu>, "CALIFORNIA - DAVID BROADWATER" <csi@thegrid.net>
Subject :  UNITED MINE WORKERS OF AMERICA - Letter from UMWA to NIOSH regarding proposed changes to Hazard ID# 10 - Re: NIOSH Replaces Biosolids Guidance - strengthens recommendations by calling for testing
Date :  Thu, 20 Jun 2002 21:23:48 -0400
Subject: Letter from UMWA to NIOSH regarding proposed changes to Hazard ID# 10 - Re: NIOSH Replaces Biosolids Guidance - strengthens recommendations by calling for testing

> Wednesday, March 20, 2002
> Mr. Frank Hearl, PE
> Deputy Director, DRDS
> National Institute of Occupational Safety and Health
> Center for Disease Control and Prevention
> Department of Health and Human Services
> 1095 Willowdale RD
> Morgantown, WV 26505
> Dear Frank,
>      In the past year, the UMWA has been aware several attacks have been
> made against NIOSH's recommendations which protects workers exposed to
> sewage sludge (biosolids). Since the UMWA is concerned with these
> crucial safety issues in regards to the land application of sewage
> sludge, and the incorporation procedure downfalls, including but not
> limited to the 300 to 360 tons per acre, we are compelled to be involved
> with any proposed changes in the Hazard ID.
>      As you are aware on June 20, 1999 John P. Acey, Jr., President of
> the UMWA (United Mine Workers of America) local 1303 requested NIOSH
> (National Institute of Occupational Safety and Health) division of the
> CDC (Centers for Disease Control and Prevention) to conduct a health
> hazard evaluation (HHE).  In the HHE request, Mr. Acey described the
> possible hazard as: "Working within feet of Non Exceptional Quality
> Class B Biosolids that contain endotoxins, pathogens, dioxins and toxic
> gasses within the restricted 30 day period will be a health hazard to
> all employees.  Mr. Acey suspected that the site restrictions
> established by EPA to protect public health from sludge exposure did not
> apply to workers.
>      Before NIOSH could schedule a visit to the UMWA mine site,
> Wheelabrator Water Technologies Inc., BioGro Division spread Class B Non
> - Exceptional Quality Biosolids on July 7, 1999 literally feet away from
> the UMWA's work area.  Thomas M. Reed and another UMWA member
> experienced dizziness, nausea and bloody vomit. Six of their co-workers
> also were sickened with flu-like symptoms. The symptoms ranged from
> burning eyes, sore throats, generation of mucus, headaches, nausea,
> vomiting , numbness of the face, skin disorders, dizziness, diarrhea,
> and other gastrointestinal symptoms.
>       On July 28, 2000 your agency, the National Institute of
> Occupational Safety and Health (NIOSH) released necessary and important
> recommendations to protect workers exposed to Class B sludge.
>      As mentioned earlier, NIOSH's recommendations; Workers Exposed to
> Class B Biosolids During and After Field Application - Hazard
> Identification # 10 has been under constant attack.  It appears entities
> profiting from the land application of sewage sludge perceive this
> document as a threat and not as a protective document as intended.  It
> is our opinion these entities are more concerned with the public's
> perception of the land application of sewage sludge rather than
> protecting workers against potential health hazards.  As an example, on
> October 31, 2000 the WEF (Water Environment Federation) and the AMSA
> (Association of Metropolitan Sewerage Agencies) cosigned a letter to
> NIOSH.  This letter stated, "AMSA, WEF are concerned about the
> implications of the NIOSH Hazard ID #10 guidance to the wastewater
> treatment industry."  The AMSA and the WEF stated, "Already, this Hazard
> ID is having a negative impact as evidenced by initiatives by both
> legislators and other outside interests, citing NIOSH's report and
> calling for the ban of Class B biosolids land application.
> Our suggested changes can correct some of the misinterpretations of
> the NIOSH report.  However, a certain amount of damage has been
> permanently inflicted on the industry." Your agency, (NIOSH) responded
> in a letter dated December 18, 2000 stating, "The recommendations
> contained in the Hazard ID do reflect what we believe to be best work
> practices to protect the health of workers."
>      Another example:  A group based in Washington, DC became involved
> with an attack on NIOSH's Hazard ID.  On March 6, 2001 the CRE (Center
> For Regulatory Effectiveness) sent a letter to NIOSH raising data
> quality issues and stating the following concerns about NIOSH's HID #10,
> "failure to seek prior consultation with parties having special
> expertise or likely to be impacted, ambiguities in the management
> recommendations that appeared likely to confuse the public, and failure
> to consider the serious unintended impacts that could result from
> issuance of the HID, and to take measures to prevent or mitigate such
> impacts." (
http://www.thecre.com/action/01-04-23.html).  The CRE letter
> mentions how the HID was quickly picked up by the nation media, and has
> resulted in pressure for bans on the land application of Class B
> biosolids.  Their letter also acknowledges the WEF/AMSA letter to
> NIOSH.  It noted the CRE's main concerns as being public perception and
> failure to seek prior consultation with parties having special
> expertise.  One must question their involvement, their objective and
> their credibility.   Another interesting fact to consider is:  CRE
> Advisory Board Member, Ron M. Linton was a Former Chairman of the
> District of Columbia Water and Sewer Authority.
> (
http://www.thecre.com/advisory.html)  From reviewing the CRE, a
> question arises. Do entities profiting from the land application of
> sewage sludge have ties with the CRE?  Please see about the CRE.  "The
> CRE has no members, but it receives from time to time, financial
> support, services in kind, and work product from trade associations and
> private firms.  Consequently, at any one time, the CRE benefits from the
> input or advice of literally hundreds of small and large firms."
> (
>      NIOSH's Hazard ID's are intended to be brief user-friendly
> documents that summarize results of NIOSH studies at specific work
> sites, that identify new or current health and safety hazards, and offer
> the best recommendation for control or prevention.  One of the main
> worksite studies NIOSH refers to in the development of their HID #10 is
> a Health Hazard Evaluation study conducted in LeSourdsville, Ohio. The
> Ohio DES (Department of Environmental Services) requested the evaluation
> because some employees reported headaches, stomach cramps, and
> diarrhea.  Since the WEF and the AMSA were unsuccessful requesting NIOSH
> make suggested changes to their HID #10 recommendations, it appears the
> LeSourdsville, Ohio study is now under attack.
>      Recently we received and reviewed an article in the Water
> Environment Laboratory Solutions publication entitled, "NIOSH Report
> Omits Significant Details in LeSourdsville Case," by MaryLynn Lodor.
> Ms. Lodor's Viewpoint article focuses on new information that was not
> provided to NIOSH during their HHE (Health Hazard Evaluation) of the
> Biosolids LandsApplication Process in LeSourdsville, Ohio.  The Butler
> County (Ohio) DES in charge of the LeSourdsville operation is now
> admitting they applied sewage sludge that exceeded the pathogen
> reduction requirements (by four times) for Class B Biosolids.
> Apparently, LeSourdsville reduced the amount of digester detention time
> causing incomplete sludge digestion, and high coliform counts. They
> acknowledge deficiencies in their treatment and testing procedures.  The
> LeSourdsville operation confesses sludge was land applied containing
> elevated coliform counts, prior to receiving the analytical test
> results.  This is a good example of the lack of oversight and the
> distinct need for more frequent testing of sludge.  Sludge especially
> that has been stock piled or stored prior to land application.
>      There are peer-reviewed studies that indicate high pathogen
> regrowth during storage. (see "Regrowth of fecal coliforms and
> salmonellae in stored biosolids and soil amended with biosolids" R. A.
> Gibbs, C. J. Hu, G. E. Ho and I. Unkovich, Institute for Environmental
> Science, Murdoch University Murdoch 6150 Australia.)  It has been
> rumored PSU has recently found this to be true during one of their
> current studies.  Stored or stock piled sludge (with pathogen regrowth)
> is typically land applied without further testing.  Why is this so?
> This mismanagement practice violates the EPA's mandatory, and required
> geometric mean concentration of coliform bacteria in sewage sludge.
> Part 503 pathogen threshold for Class B status must not exceed two
> million (2,000,000) CFU per gram of sample.  Sludge that may have met
> the Class B criteria at one time may exceed the threshold after
> storage.  It is evident, that along with pathogen regrowth comes
> increased health risks and elevated odors.  New studies have concluded,
> sludge odors and odorants can adversely impact human health, including
> eye, nose and throat irritation, headache, nausea, cough, shortness of
> breath, palpitations, etc. (see The Journal of Agromedicine Volume 7,
> Number 1 2000 - ISSN: 1059-924X - Dr. John Walker of US EPA and Dr.
> Susan Schiffman of Duke University as lead authors).  Not by
> coincidence, these are the exact symptoms experienced by our mine
> workers on July 7, 1999.  These illnesses were the UMWA's basis for
> requesting a Health Hazard Evaluation.
>      In regards to LeSourdsville, Ohio, Ms. Lodor's article insinuates
> NIOSH erred in their HHE conclusion that suggested men became ill after
> being exposure to Class B, stating the DES now asserts most of the
> health complaints can be traced to non-Class B material that workers
> handled. Ms. Lodor's article failed to address, and mention imperative
> information surrounding NIOSH's conclusion.
>      It is evident from reviewing the LeSourdsville HHE 98-0118-2748
> report that NIOSH collected 18 sample sets of sludge during their
> evaluation, and the geometric mean concentration of coliform bacteria in
> the bulk sewage sludge samples were 270,000 CFU per gram of sample.  The
> analysis of these samples indicate the pathogen reduction was well below
> the Part 503 pathogen threshold for Class B status, yet NIOSH found and
> detected enteric bacteria in these same samples.  NIOSH not only
> detected opportunistic human disease causing pathogens in the bulk
> samples but also found and identified them in air samples which were
> collected as well.  NIOSH made their conclusions from the analysis of
> these samples which indicate the potential for occupation exposure to
> disease-causing organisms by inhalation or ingestion of the sludge.  It
> is clear, NIOSH's conclusion and the issuance of HID#10 was based on
> good science.  Science that is definitely supported by data collected at
> the LeSourdsville, Ohio site.
>      Whether LeSourdsville, Ohio DES claims men were getting ill during
> a time when the sludge did not met Class B criteria means very little.
> The fact remains, NIOSH detected airborne pathogens during a time that
> the sludge was well within Class B criteria.  More importantly, some of
> the opportunistic human disease causing organisms identified by NIOSH
> will indeed cause the same symptoms and illnesses that these men
> experienced.  This evidence more than supports NIOSH's LeSourdsville HHE
> conclusion.  However, the article still insinuates the men's illnesses
> improved after DES corrected it's sampling process and after they took
> additional workplace precautions. An important point that must be made
> is; Ohio DES was not expecting NIOSH's study to conclude sludge was the
> cause of the men's illnesses.  Ohio DES has since stated they requested
> the HHE with the hopes NIOSH would prove sludge was not the cause of
> illness.
>      Although WELS's viewpoint article appears to be written to
> discredit NIOSH's Hazard ID, LeSourdsville's confession, and the article
> actually exposes several severe mismanagement practices in regards to
> the land application of sewage sludge (biosolids).  Mismanagement
> practices which may not only effect worker's health, but the health of
> residents living near sludge sites as well.
>      LeSourdsville is an excellent example of very serious problems that
> can occur at any given time, at any given facility.  It is not realistic
> to assume each self regulated facility is following EPA guidelines.  The
> LeSourdsville confession clearly indicates the need for more frequent,
> independent testing, and the need for increased oversight.  Without
> proper testing and oversight, mismanagement practices will occur
> therefore increasing health risks.
>      Another area that needs addressed that is not contained in HID 10
> or in your new proposal is the current use of indicator organisms.
> PAG-7 General Permit states that Exceptional Quality Sewage Sludge must
> meet standards for either fecal coliform or salmonella.  The National
> Academy of Science, NRC study found that Part 503 Class A sludge methods
> used to determine if pathogen standards have been met is questionable.
> The study found problems with the prescribed test for salmonella and
> recommended the salmonella test not be used in evaluating sludge as
> Class A unless it is used along with the fecal coliform test.
> Currently, either a fecal coliform or salmonella test may be used to
> show that Class A microbiological requirements are met.
>      The NRC explained that the presence of coliform bacteria as an
> indicator organism may not accurately predict the presence of viruses,
> protozoa, or helminth.  In addition, the NRC report recommended that the
> EPA reevaluate the 30 day waiting period for grazing after Class B
> sludge is applied to fields.  This recommendation was due to a finding
> in Denmark that tapeworms may survive in sludge-treated fields for up to
> one year.  The concern of long term survival of helminth, e.g.
> tapeworms, in biosolids was voiced by scientists at the Cincinnati
> workshop.  Scientists at this workshop discussed the need for research
> on better methods and indicator organisms to test for pathogens in
> biosolids.  This again is good sound science that needs addressed for
> the protection of public health and safety.  Not for perception.
>      NIOSH's HID recommendations are needed, and are very crucial to
> workers who are not warned or trained to handle Biosolids.  These
> workers, include but are not limited to, truck drivers who physically
> get inside their truck's beds to shovel sludge which is caked inside,
> mine workers who are frequently asked by sludge companies to use their
> mining equipment to load their sludge spreaders and routinely work in or
> next to sludge site.  We highly recommend, NIOSH maintain the HAZARD
> name and also stress the content not be weakened as prescribed in your
> proposal.
>      Please find below, our comments on the changes in your proposal and
> items which were omitted in the proposal from HID 10 by a side by side
> comparison  with HID 10:
>  The key word Hazard is omitted.
>             Comment: Our position is that the word Hazard is there for a
> reason.  It has had a great                                    impact
> throughout the country in identifying and labeling such a
> hazardous                                     material to protect and
> insure the health and safety of the workers exposed
> to                                  this dangerous material.  We do not
> believe that NIOSH's commitment to
> protect workers health and safety should be compromised by any
> entity                                           whose main concern is
> one of profit and public perception.  The word
> Hazard                                 should remain as is.
> Bullet one in HID 10 is omitted in the proposal . "Workers may be
> exposed to disease-causing organisms while handling, applying, or
> disturbing Class B biosolids on agricultural  lands or mine reclamation
> sites."
>            Comment: We believe the original verbiage and intent should
> remain in tact as is in                                         HID10.
> Bullet number 4 in HID 10 is omitted in the proposal.  "NIOSH collected
> air samples for bacteria and endotoxins (a component of some bacteria),
> and bulk sewage sludge samples for fecal coliform bacteria at a Class B
> biosolids land application processing facility.
>             Comment: We believe this was removed as a result of the DES
> claims from the
> LeSourdsville HHE where men became ill from exposure to sludge, and
> the                                    procedures that followed.  Our
> position is it should remain in tact as is
> in                                        HID 10.
>  On the top of page two of your proposal you talk about the percentage
> of biosolids             generated in the United States and its use.
>             Comment: Why is this included?  It is almost like a
> promotion for the use of Sludge.
> Page two and three of your proposal under, "Can workers be exposed to
> pathogens from biosolids?"  You have omitted: The environmental sampling
> results indicated that the gastrointestinal illnesses were possibly of
> occupational origin.
>             Comment: We believe again, the new verbiage has weakened the
> intent as was in the                                       original
> language, as was found under Description of Hazard bullet
> number                                    one.  The verbiage as written
> in HID 10 should remain in tact as is.
> Page three of your proposal under, "Can workers be exposed to pathogens
> from biosolids?"  Second bullet on page three, "NIOSH collected bulk
> samples, etc."  You have omitted: The mean fecal coliform concentration
> of the bulk samples was 220,000 CFU per gram of sample (wet weight).
>             Comment: We believe this is a crucial statement showing the
> pathogen reduction was                                      well below
> the Part 503 pathogen threshold for class B status.
> However,                                         NIOSH found and
> detected enteric bacteria in these same samples.
> The                                          detection of enteric
> bacteria in a  limited number of air and bulk
> samples                                  confirms the potential for
> workers to be exposed to organisms which
> have                                 been associated with
> gastrointestinal symptoms and illnesses.  (As
> taken                                     from HID 10) The verbiage as
> written in HID 10 should remain in tact as is.
> Page four of your proposal under, "Extend good environmental practices
> to prevent and minimize occupational exposures."  You have omitted what
> was contained in Engineering Controls: The storage time for dewatered
> (filter cake) Class B biosolids should be minimized at both the water
> treatment facility and in the field to prevent the growth of pathogens.
>             Comment: Here again we find by omitting pertinent verbiage
> from a document can alter                                  it's entire
> meaning and intent.  The verbiage as written in HID 10
> should                                         remain in tact as is.
>      The changes proposed by NIOSH is a retreat from protecting workers
> exposed to the clear health risks of contaminated sewage sludge.  We
> also believe the changes you are proposing are premature, considering
> the upcoming release of the National Research Council's report, the
> EPA's OIG report and the EPA's "Workshop on Emerging Infectious Diseases
> Agents and Issues Associated With Biosolids" report.  There are mounting
> claims and studies indicating sludge may be causing great harm.  One
> study mentioned in the EPA's OIG report states, "Twenty one (21)
> separate incidents of illness or death, in which exposure to sludge was
> identified as a possible cause." "There were three deaths alleged to be
> caused by land application, as well as ground water and well
> contamination.  Health problems cited were: coughing; choking in sleep;
> skin rashes; gastrointestinal symptoms; eye, nose, throat and lung
> irritation; asthma; nausea, dizzy spells; flu-like symptoms; and immune
> system damage."  For more information on victims from sludge exposure
> please visit:
> Again these symptoms are exactly what our members experienced.  We
> believe the science and evidence are strongly suggesting Class B sludge
> is the cause of these illnesses, therefore we urge  NIOSH to leave the
> HAZARD name in HID # 10.
> We request before any changes are made, the UMWA be given the
> opportunity to review all correspondences, email, letters and papers
> associated with HID#10.  This would include correspondences from, but
> not be limited to the CRE, WEF, EPA, AMSA and affiliates.  Please advise
> the UWMA if a Freedom Of Information Act Request is necessary.
> The UMWA would like to take this opportunity to thank NIOSH for the
> development and release of HID#10.
> James P. Lamont
> United Mine Workers of America
> International Representative
> 51 Eleventh Street
> P.O. Box 200
> Lucernemines, Pa. 15754

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