Letter to the Editor – Virginia Biosolids Council Promotes False Information

The 4/10 Letter to the Editor by Barry Dunkley, President of Virginia’s  industry-funded Council promoting  biosolids, contains false and  misleading information about my credentials as well as false and misleading information about the safety of using  biosolids as fertilizer.

I have never represented myself as a scientist, as Mr. Dunkley claims. I continue to consult many  scientists  as I  focus on issues dealing with science and public policy.   While working on my Harvard  Ph.D.  I researched the interrelationship between science and the humanities. That led me to design and teach interdisciplinary   environmental science courses at RIT’s College of Liberal Arts.  The College’s mission is “to produce graduates that can balance an understanding of science and technology with social considerations and to make future engineers and scientists aware of the ethical, environmental  and social impacts of their respective fields.” Much of my long university teaching career was directed toward that end. The courses and programs we introduced in the late 1970s  evolved into RITs current interdisciplinary degree programs in Science, Technology, and Public Policy.

At RIT I achieved the rank of tenured Full Professor and chaired the Department of Science, Technology and Society. Since then I have focused my research on biosolids, especially on how industry works with environmental agencies to deceive the public about the safety of biosolids  by funding  an elaborate Public Acceptance Campaign. One part of this campaign is to deliberately ignore, malign, and discredit  scientists and citizens who criticize  the current policy.   Contrary to Mr. Dunkley’s claim, my research has resulted in several peer reviewed articles published in mainstream scientific journals, e.g.  IJOEH_1104_Snyder.pdf. It also resulted in written testimony  submitted to the US Senate Environment and Public  Works Committee: http://www.sludgefacts.org/EPWtestimony.pdf.

In his official National Academy of Sciences Press Release, panel chair, Thomas Burke, stated   that the sludge regulations are based on outdated science: http://www8.nationalacademies.org/onpinews/newsitem.aspx?RecordID=10426.  Burke also stated that there is an urgent need for health studies and tracking  reported sludge-related illnesses.  Former EPA Senior Level research microbiologist David Lewis and his team of scientists had already started to document and explain why  sludge-exposed neighbors were experiencing serious health problems, especially respiratory illnesses. http://www.biomedcentral.com.   After the report of a second sludge-related death in Pennsylvania, EPA finally  conceded on CBS Evening News that it could no longer guarantee that the practice was safe and that the agency needed to “revisit” its land application policy.   http://www.cbsnews.com/stories/2003/10/29/eveningnews/main580816.shtml

That the current regulations do not protect agriculture has been confirmed in countless published scientific documents, many of them generated by internationally renowned soil scientists at the Cornell Waste Management Institute. http://cwmi.css.cornell.edu/sewagesludge.htm

Two prize-winning dairy herds near Augusta GA were destroyed  after  hundreds of animals sickened and died from ingesting  forage grown on sludge- treated land. http://www.sludgenews.org/resources/documents/Nature.pdf .  Milk samples from some of the affected animals  contained  thallium levels 120 times the concentration that is considered safe in drinking water:  http://www.organicconsumers.org/articles/article_10789.cfm.  Major food processing companies—Heinz, DelMonte, Western Growers—do not accept produce grown on land that has been treated with biosolids.  A 2008 Nature editorial called the entire US biosolids program “an institutional failure spanning more than three decades.”

I have provided readers with a number of important links.    I challenge Mr. Dunkley to do the same. For a start, Mr. Dunkley might want to provide the links to peer reviewed  published articles that substantiate his claim  that “thousands of scientists have concluded that the  land application of biosolids is safe”.

Caroline Snyder Ph.D.

Emeritus professor

Rochester Institute of Technology

458 Whiteface Rd.

N.Sandwich NH 03259



  1. Dr. Snyder’s letter is well thought-out and persuasive. It comes in support of many people’s instinctive reaction to extracting the sludge residues out of sewage with a costly wastewater treatment plant process, then dumping them right back on the land. It simply doesn’t pass the smell test (pardon the pun).

    I went out onto the DEQ website, to find the latest information I could concerning the testing done on sludge as currently mandated. In their 2008 “Biosolids FAQs” 4-page comment, they indicate the following:

    How do we know what’s in biosolids?
    DEQ regulations require sampling on a prescribed schedule to ensure that the regulated parameters are measured and treatment levels are achieved. The nutrient content of the material is measured so that the appropriate rate for the crop to be grown can be determined. The frequency of testing depends upon the amount of biosolids a particular generator produces – more production requires more frequent sampling. At a minimum, the following parameters are analyzed:

    Nutrients: – Total kjeldahl nitrogen – Ammonia nitrogen – Nitrates – Total phosphorus – Total potassium.

    Metals: – Arsenic – Cadmium – Copper – Lead – Mercury – Molybdenum – Nickel – Selenium – Zinc

    Other: – Percent solids – Volatile solids – pH – CaCO3 (for lime stabilized biosolids) – Alkalinity as CaCO3 – Additional parameters may be analyzed for screening purposes when approving a new source. For example, analysis for PCBs (poly-chlorinated biphenyls) is required before a new biosolids source will be approved.

    What is of concern here is all of those things that are NOT being tested in the sludge. In addition to thallium, I feel sure that Dr. Snyder could provide a list of items that would give rise to serious questions – I feel sure that hormones and other chemicals would be among them, given the transgender fish and fish-kills that we see so frequently.

    Until such time as the DEQ makes a more determined effort to protect this nation’s water supply with truly comprehensive testing, I will apply that common sense rule: “when in doubt, don’t”.