UNITED MINE WORKERS RESPOND
TO CHANGES IN NIOSH'S HEALTH HAZARD ID REPORT FOR SLUDGE/BIOSOLIDS
WORKERS -- [CHANGES WERE FORCED BY EPA/WASTE INDUSTRY
HARASSMENT AND INTIMIDATION OF NIOSH]
UMWA DESCRIBES ADVERSE
HEALTH EFFECTS SUFFERED BY MINE WORKERS EXPOSED TO CLASS B SEWAGE
SLUDGE:
DIZZINESS, NAUSEA, BLOODY
VOMIT, FLU-LIKE SYMPTOMS, BURNING EYES, SORE THROATS, THICK MUCUS,
HEADACHES, NUMBNESS OF THE FACE, SKIN LESIONS AND GASTROINTESTINAL
SYMPTOMS
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."
>
(http://www.thecre.com/about.html)
> 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: http://www.sludgevictims.net/>
> 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
>
>
>
>
>
> | |
