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Biosolids: More Harm than Good, Part 1

David Lewis, Ph.D., formerly a senior-level research microbiologist at EPA-ORD, was terminated by EPA for publishing two articles in Nature that raised concerns over the 503 sludge rule. He currently serves as director of research for the Focus for Health Foundation. Dr. Lewis kindly agreed to an interview for the MOTHER EARTH NEWS blog addressing the issue of agricultural use of sewage and industrial sludge, aka – biosolids. He is one of the most prominent scientific voices in the growing opposition to biosolids land application. Dr. Lewis’ publications are frequently cited as an example of solid, unbiased scientific evidence of the danger posed by this practice. Read Part 1 of this interview below and Part 2 here.

Lidia: Dr. Lewis, thank you so much for taking your time to address this issue today. Let’s start with clearing up some confusion with the nomenclature. Is there a difference between “sewage sludge” and “biosolids”? Or it is just a different name for this same thing, which is simply a municipal waste?

Dr Lewis: Sewage sludge is semi-solid organic matter, mostly human feces and animal fats, which settles out at wastewater treatment plants. More than half of the sewage sludges produced in the United States are biologically and chemically treated, usually by adding lime, to reduce odors and indicator pathogen levels. Once treated, the product is called biosolids. It is repeatedly applied to farms, forests, school playgrounds, public parks and other public and private lands at rates measured in tons per acre.

Lidia: Does the EPA’s Part 503 rule, a regulation that’s intended to protect public from potential health dangers of biosolids, deliver on its promise?

Dr Lewis: After promulgating the 503 rule, EPA’s Office of Water reneged on a promise it made to fund EPA’s Office of Research & Development (ORD) $10 million to improve the science. It regulates only nine of 27 heavy metals found in sewage sludge (As, Cd, Cu, Pb, Hg, Mo, Ni, Se, Zn), and no toxic organic chemicals. Many chemicals found at high (ppm) levels in biosolids are the worst of the worst, which EPA lists as priority pollutants. These are the ones we worry about most. They are highly persistent, biomagnified up the food chain, and known to cause adverse health effects in humans and animals.

Priority pollutants include endocrine disruptors, pesticides, pharmaceuticals, plasticizers and other chemical groups that concentrate in animal fats. As the fat solubility of chemicals increase, so does their neurotoxicity. Not surprisingly, exposures to these chemicals are linked to autism, ALS, Alzheimer’s disease, Parkinson’s disease and other neurological diseases and disorders.

Lidia: The concept of spreading the wide array of contaminants, pollutants, pathogens and toxins on the agricultural land – whose idea was it in the first place and why?

Dr Lewis: When EPA was first created, industrial wastes containing such pollutants were discharged into rivers. From there, they were carried away from our cities, and diluted to parts-per-trillion or lower levels in the oceans. EPA’s solution to pollution was dilution. But, with the promulgation of the 503 sludge rule, EPA’s approach changed to concentrating pollutants on land—where we live, work and play—at millions of times higher levels than allowed elsewhere under the Clean Water and Clean Air Acts.

Lidia: Isn’t that a contradiction to the mission of the EPA, which after all is the Environmental Protection Agency? This practice goes against the common sense of protecting the environment! But let’s forget the environment for a moment, what about protecting public health?

Dr Lewis: Not to worry, says the EPA, the wastewater industry, and major polluters. They point to a virtual absence of scientific evidence documenting illnesses and deaths in the scientific literature, and assure the public that pollutant-laden dust particles from fields covered with biosolids, and water from biosolids-contaminated private wells, do not cause any adverse health effects worth mentioning. Yet, air and water contaminated with the same chemicals from other sources at far lower concentrations are known to damage the immune system and cause cancer, birth defects, and neurological disorders. How can this be? EPA’s answer, believe it or not, is “magic.”

Dr. Alan Rubin in EPA’s Office of Water explains:

Sludge magic [means] there are unique properties in the biosolids matrix that sequester metals [and] organics [and] significantly reduce, if not eliminate, movement of pollutants from the biosolids out to the environment. The processes, some of them are understood, some of them are not that well understood, but the whole thing taken together is called magic.

Lidia: Did he really say – “magic”? So it’s the sludge magic that contributed to the scientific basis of Part 503 rule??? What did the scientific community have to say to that?!

Dr Lewis: Of course, peer-reviewed scientific journals would reject the idea of using magic as a basis for supporting regulations aimed at protecting public health. So, to create a body of “scientific” literature supporting the 503 sludge rule, EPA established a cooperative agreement with the Water Environment Federation, the wastewater industry’s largest trade association, to fund a National Biosolids Public Acceptance Campaign. Under that agreement, scientists at USDA-supported agricultural colleges were funded, while scientists who linked biosolids to adverse health effects were systematically blacklisted, even accused of research misconduct. To support the sludge rule, EPA and the USDA supported skewing, and even fabricating, the data.

Lidia: Do you know any examples of skewing the data used by EPA?....

Dr Lewis: A good case in point is a study EPA funded at the University of Georgia (UGA), which EPA, the USDA, and a National Academy of Sciences panel used to dismiss cattle deaths on two dairy farms where biosolids from the City of Augusta, Georgia were applied. When the study was published in 2003, UGA issued a national press release in which lead author Julia Gaskin stated: "Some individuals have questioned whether the 503 regulations are protective of the public and the environment. This study puts some of those fears to rest.”

In 2008, Nature published an editorial and news article about a federal court decision stating that environmental monitoring data in the Gaskin study were fabricated by the City of Augusta. When deposed about the fake data in a qui tam lawsuit, which the dairy farmers and I filed, Rufus Chaney, the scientist managing USDA’s biosolids program, supported the use of fabricated data:

Question: Ms. Gaskin could have totally made up all that data and you would still rely on it because it was in a peer-reviewed study; is that accurate?

Answer: As long as it—as long as it was in general agreement with general patterns established in hundreds of papers....

Lidia: Dr. Lewis, in the light of those facts you just explained, the fate of the agricultural soils treated with biosolids looks rather grim. The human exposure to the pollutants present in the biosolids will likely increase in the future. What can be done to change that?

Dr Lewis: Soil remains the only part of the earth where high (ppm) levels of even the most harmful pollutants can be released unregulated. Instead of applying them to land, they should be reduced to simple inorganic compounds using new technologies, such as supercritical water gasification. Pollutants with serious adverse health effects should be destroyed rather than releasing them into the environment and regulating only a tiny fraction of them. To this end, Congress should pass a Clean Soil Act, and make polluters responsible for destroying toxic organic chemicals and recovering metals and radioactive elements at the source.

Reference documents supporting this article appear in Dr. David Lewis book, Science for Sale (Skyhorse Publishing, NY. 2014), and other writings and interviews:

How the EPA Faked the Entire Science of Sewage Sludge Safety: A Whistleblower's Story

Dr. Mercola Discusses Biosolids with Dr. Lewis (Full Interview)

Read Part 2 of my interview with Dr David Lewis. We will talk about his research at EPA exposing the harmful effects of biosolids land applications, the reaction of the EPA to his publications, how that affected his professional career and what he did about it. We will also share stories about the extraordinary "ordinary" people opposed to the biosolids agricultural use and how they advocate for our health and the environment.

Lidia Epp is active with a local group of residents concerned about the agricultural application of biosolids, a dangerous practice that devastates farmland. She corroborates with local activists, politicians and scientists to bring public awareness to this issue and advocates for changes in state and federal regulations of biosolids land use. Read all of Lidia’s MOTHER EARTH NEWS posts here.

All MOTHER EARTH NEWS community bloggers have agreed to follow our Blogging Best Practices, and they are responsible for the accuracy of their posts. To learn more about the author of this post, click on the byline link at the top of the page.

6/13/2016 9:14:34 AM

What is this article/author/phD telling the common household? How should I dispose of my kitchen/bathroom waste? How does permaculture play with all this science?

3/1/2016 4:12:27 PM

Dear Steve Wilson... your quote "Class A biosolids products are subjected to further treatment by processes like composting and thermal drying, and are considered pathogen free"... Who exactly is CONSIDERING the Class A concentrated toxic sewage sludge---- PATHOGEN FREE? It is either pathogen free or not... There should be no "consideration". Maybe the 'sludge industry' that you work for or the EPA, or a state agency--- looked at it and 'considered' it pathogen free. Additionally, will it continue to BE PATHOGEN FREE? and what pathogens were tested for.. and not tested for?

2/29/2016 6:09:07 PM

Steve Wilson, a Project Manager for Brown and Caldwell, provides consulting services to the federal government and biosolids industry. Not surprisingly, he’s upset over research I published as a senior-level (GS-15) U.S. EPA Research Microbiologist in Nature and other leading peer-reviewed scientific journals documenting adverse health and environmental effects of biosolids. I was even presented the Science Achievement Award by EPA Administrator Carol Browner for my research demonstrating how climate change can affect the toxicity of chemical groups found in biosolids. This must be very disconcerting to someone who earns his living trying to convince federal agencies that “sludge magic,” as most EPA research scientists called it, is really true. That is, all of the same chemical pollutants known to cause cancer, birth defects, neurological disorders, and a host of other health problems in air and water are perfectly safe when spread on school playgrounds and home gardens at millions of times higher concentrations. He must really believe it because he uses that same “logic” to argue that biosolids “consist primarily of microbial biomass,” not human feces. Surely someone who promotes biosolids for a living must be aware that human feces is, in fact, primarily microbial biomass. David L. Lewis, Ph.D., Research Director, Focus for Health Foundation

2/29/2016 3:16:07 PM

I am very disappointed to read that Steve Wilson still has no clue about the constituents in sewage sludge processed or otherwise. If he was to look at anything other than EPA research from the 70 and 80s he would get a clear picture. He obviously works for the sewage industry. Had he read the EPA's Office of Inspector General's report 09/2014 # 14-P-0363 he would see how CFR 40-503 is failing and industrial pretreatment is a joke and has been since conception. If he was studied on the single indicator organism tests he would not make an ignorant statement that sewage sludge, processed or not, can be free of pathogens under any process. If you want truthful and factual information on CFR 40-503 may I suggest first looking at what Steve is talking about then do searches on sewage sludge for information outside the sewage industry and make your mind up from reading both. In fact if you want a real a real scare, read EPA’s CFR 40- 503 risk assessment or the EPA’s Targeted National Survey of Sewage Sludge These are the sewage heads that protect this ill-conceived practice: US Legislature / EPA, USDA, NAS / State Legislature/ State Environmental Agencies / River Authorities/ Municipalities / the multi-billion dollar Waste Water Processing Plants (WWPP), sludge dumpers and even some colleges who get grants from the state and sewage syndicates. Steve would be your typical sewage con artist. Craig Monk

2/29/2016 1:47:04 PM

I am very disappointed to read that the Mother Earth News supports "sludge activists" like Dr. Lewis. Dr. Lewis clearly doesn't even understand the fundamentals of wastewater treatment when he describes biosolids as "mostly feces and animal fats" in your interview. Biosolids consist primarily of microbial biomass from the secondary wastewater treatment process. They are commonly treated by anaerobic digestion to provide stabilization and harvest biogas for renewable energy production. Class A biosolids products are subjected to further treatment by processes like composting and thermal drying, and are considered pathogen free. The conspiracy theories described by activists are tiresome. If you want truthful information about the many benefits of biosolids recycling in agriculture, contact your local Ag Extension agent or the many legitimate science-based publications available online.

2/21/2016 1:29:12 PM

Because of so many health complaints from sludge-exposed rural neighbors, the National Academy of Sciences (NAS) convened a panel to review the scientific basis of the sludge rule. Ellen Harrison, then Chair of the internationally renowned Cornell Waste Management Institute, served on the NAS panel. When deposed in 2003 she said "despite the incredible flack David was getting he put forward reasonable scientific theories backed by some research that there were plausible routes of exposure and that in fact illness might be resulting. . . . David was probably the most important player in all of this." Yet all references to Dr. Lewis' published and unpublished manuscripts were removed from the 2002 NAS report, so EPA and industry could continue to claim that sludge never made anyone sick. See Science for Sale, p. 67.

2/21/2016 11:40:12 AM

Thank you Dr. Lewis for a very helpful and informative article. Given the recent revelations in Flint, Michigan, people should be more skeptical and concerned than ever about government's failure to protect the health and safety of its citizens. This includes the EPA not effectively regulating toxic sewage sludge and that it makes its way into consumer products like compost. That people assume compost containing 'biosolids' (sic) is safe and even use it to grow food they then consume is a betrayal of the people by their government.

2/20/2016 10:28:14 PM

where is my previous post?

2/20/2016 7:04:21 PM

Having lived among 19 sludged fields that have been spread with concentrated toxic sewage sludge for 30 years... I can personally attest to the facts stated by Dr. Lewis. Disposing municipalities' toxic waste on land devastates human health, quality of life, surface and ground water, air, food quality and wildlife. Learn more by going to and see Sewage Sludge Action Network on Facebook, for day-to-day articles opposing this "practice" through out the world!