Spew #  [014]  --   Look closely at the Baltimore Orgro Lead Contamination Study:

by Maureen Reilly

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.

How does the Ontario Government respond to contaminated properties?

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 that is causing an 'adverse effect' and that when the provincial government became aware of the problem they would order the property owner to remediate the yards. 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 develop 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. The point is not to just dilute the problem contamination but to isolate and remove the high concentration contaminated soil. 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 from being dispersed throughout the community.

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 said to be 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 smelter was once in the neighborhood.

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

So in Baltimore, rather than spending a half million to remove the lead from these properties, Farfel, Chaney, et al were given nearly a half million dollars in government funds to undertake this research 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.

Third - They did not rope off or fence off the now bare soil yards. There was nothing to stop people from walking across the bare soil, crushing the grass seedlings, and tracking the lead and sludge contaminated soil into homes and cars -tracking it into dust to blow around the neighborhood.

Did they maintain the yards? 

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

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?

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-amended lead-contaminated soil would result in lower lead levels in the childrens' 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 childrens' blood - neither before nor after the experiment. They did not check for lead, they did not check for sludge related diseases or conditions either.

What the researchers DID DO was to leave 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.

Why were the residents not told that sewage sludge compost would be brought to their homes?

Why did the researchers not disclose the levels of all the Part 503 and Maryland state sludge compost requirements for toxic metals and PCBs?

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? Why is all the historic analytical data for Orgro toxic metals in the form of ‘personal communications’ and not lab reports?

The researchers declared the experiment a success - because they said that the bioavailability of the lead in the ammended soil was lower in the final soil than in the unammended 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 endotoxin 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 their own hazardous lead home improvement project - these researchers arguably endangered these families.

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, testing what is underneath, and representing the results as an accurate sampling of the community exposure ? Would the local families scrape off the top level of soil and be exposed to the under soil? 

No. At the year’s end, the community would be most exposed to the top level of soil…the soil that was not tested.

But the journal "Science of the Total Environment" refuses to say who peer reviewed this paper.

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 9^th yard? Why is there no yard by yard data? Why are the data all averaged?

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 follow-up 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.

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?

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 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?

This piece of fiddled research was meant to provide academic cover to use sewage sludge to ‘remediate’ poor contaminated neighborhoods.

Even though there is absolutely no evidence that this treatment reduced lead exposures or improved local health, the study participants declared that "this study confirms the viability of in situ remediation of soils in urban areas where children are at risk of high Pb exposure from lead in paint, dust, and soil."

It confirms no such thing. After the sludge application not even one of the 9 yards had their soil levels reduced to under the EPA lead in soil limit of 400 ppm.

All the properties still tested out at over 400 ppm lead – over the childrens playground limits for lead - at the close of the experiment.

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