Friday, June 14, 2002

New Occupational Health and Safety Guidelines for Land Applied Sewage Sludges

GUIDANCE FOR CONTROLLING POTENTIAL RISKS TO WORKERS EXPOSED TO CLASS B
BIOSOLIDS
June 12, 2002
Center for Disease Control, Workplace Safety and Health
http://www.cdc.gov/niosh/docs/preprint/pdfs/biosolidsb.pdf
PREPRINT
Introduction
Biosolids are the organic residues resulting from the treatment of
commercial, industrial, and municipal wastewater (sewage). One purpose
of
the treatment is to significantly reduce the concentration of
disease-causing organisms (also known as pathogens). Treatment also
reduces
the attractiveness of the residues to insects, birds, and rodents. The
product is a material that can be recycled for uses such as adding
organic
material to the soil.
The U.S. Environmental Protection Agency (EPA) has established two
categories of biosolids: Class A biosolids have undergone treatment to
the
point where the concentration of pathogens is reduced to levels low
enough
that no additional restrictions or special handling precautions are
required
by Federal regulations. If the Class A biosolids meet exceptional
quality
requirements for metals content, they may be sold in bags and applied in
the
same way as other soil conditioners such as peat moss.
Class B biosolids have undergone treatment that has reduced but not
eliminated pathogens. By definition, Class B biosolids may contain
pathogens. As a result, Federal regulations for use of Class B biosolids

require additional measures to restrict public access and to limit
livestock
grazing for specified time periods after land application.
This allows time for the natural die-off of pathogens in the soil.
Whereas EPA rules (40 CFR Part 503) restrict public access to lands
treated
with Class B biosolids in order to protect public health, these rules do
not
apply to workers involved with Class B biosolids handling and land
application. Workers may come in contact with Class B biosolids during
the
course of their work. Workers and employers may be well aware of the
need
for precautions when contacting untreated sewage, but less aware of the
need
for basic precautions when using Class B biosolids. This document
provides
information, guidance, and recommendations to employers and employees
working with Class B biosolids to minimize occupational risks from
pathogens. It does not address other potential safety and health issues
such
as injuries or exposures to chemicals.
How are biosolids used?
Biosolids are typically treated to Class B or Class A standards at the
wastewater (sewage) treatment plant, where a liquid or semi-solid
material
is produced. In a liquid state, biosolids can be transported by truck to
a
land application site where they are applied directly to the land using
tractors, tank wagons, irrigation systems, or special application
vehicles.
Alternatively, biosolids may undergo mechanical dewatering that may
include
the use of polymers. Dewatered and liquid biosolids are often
temporarily
stored at the treatment plant or application site. Dewatered biosolids
are
transported and applied to land using front-end loaders, trucks,
tractors,
or biosolids-spreading equipment. Most biosolids are applied with
spreaders
in semi-solid form and then incorporated into the soil using a disc
plow.
Workers may come into either direct or indirect contact with biosolids
during any phase of the treatment, transport, or application process, or

after they are land applied. Currently, more than fifty percent of the
biosolids generated in the United States is recycled as soil
conditioners to
improve and maintain productive soils and stimulate plant growth, rather

than being sent to landfills or incinerated. Biosolids are applied on
agricultural and forestlands and surface mine reclamation sites, and
Class A
biosolids are also used in horticultural applications. EPA estimates
that
7.1 million tons of biosolids were generated for use or disposal in
2000.
What is in biosolids that requires control of worker exposures?
There are four major types of human disease-causing organisms
(pathogens)
that can be found in sewage: (1) bacteria, (2) viruses, (3) protozoa,
and
(4) helminths (parasitic worms). Class B biosolids may contain the same
types of pathogens as the source sewage, but at reduced concentrations.
Both
Class A and Class B biosolids may also contain chemicals (including
metals)
and allergens.
To protect public health, the EPA¹s 40 CFR Part 503 rule prescribes a
restricted period of up to one year to limit public access to lands
where
Class B biosolids have been applied. These EPA restrictions do not apply
to
occupational access. EPA does recognize that occupational exposure can
occur, and states that workers exposed to Class B biosolids might
benefit
from several additional precautions such as use of dust masks when
spreading
dry materials, the use of gloves when touching biosolids, and routine
hand
washing before eating, drinking, smoking, or using the restroom.
The risk of worker exposure to infectious agents in Class B biosolids is

likely greatest prior to, during, and immediately after land application
of
the biosolids. Because the concentration of pathogens declines through
natural processes, the potential for pathogen exposure decreases over
time.
Do we know these pathogens can cause disease?
Yes, the association between poor hygiene, raw sewage, and infectious
disease is well established. Most of the pathogenic bacteria, viruses,
and
parasites in biosolids are enteric, which means they are present in the
intestinal tracts of human and animals. Enteric organisms that may be
found
in biosolids include, but are not limited to, Escherichia coli,
Salmonella,
Shigella, Campylobacter, Cryptosporidium, Giardia, Norwalk virus, and
enteroviruses. Exposure may potentially result in disease (e.g.,
gastroenteritis), or in a carrier state where an infection does not
clinically manifest itself in the individual but can be spread to
others.
These enteric organisms are usually associated with self-limited
gastrointestinal illness but can develop into more serious diseases in
sensitive populations such as immuno-compromised individuals, infants,
young
children, and especially the elderly.
The disease risk is a function of the number and types of pathogens in
the
Class B biosolids relative to the exposure levels and infective dose.
Because data are sparse on what constitutes an infective dose, it is
prudent
public health practice to minimize workers¹ contact with Class B
biosolids
and soil or dusts containing Class B biosolids during production and
application, and at land applications sites during the period when
public
access is restricted. Class A biosolids may also present some health
risk to
workers since some chemicals and biologic constituents in Class A
biosolids
are not regulated by the EPA.
Can workers be exposed to pathogens from biosolids?
Workers could be exposed to pathogens and irritants when working with
Class
B biosolids during the period when public access is restricted. During a

NIOSH field investigation at one biosolids land application and storage
site, which did not comply with EPA requirements, the following was
observed:
NIOSH interviewed employees who worked in all phases of the biosolids
operation.
Some employees reported repeated episodes of gastrointestinal illness
after
working with the biosolids, either at the treatment plant or during land

application.
NIOSH observed among workers an inconsistent awareness, provision, and
use
of protective equipment and hygiene practices appropriate for handling
Class
B biosolids (or biosolids that do not comply with EPA standards).
NIOSH collected bulk samples from different locations within the
biosolids
storage site and found measurable concentrations of fecal coliforms.
Fecal
coliforms are used as an indicator for the presence of other enteric
microorganisms. Enteric bacteria were detected in air samples collected
at
the land applications site.
The local department of environmental services recently informed NIOSH
that
biosolids applied at this site intermittently exceeded (by up to
4.5-times)
the EPA fecal coliform upper limit for Class B biosolids prior to the
NIOSH
survey.
The sub-standard biosolids were applied at the agricultural site before
the
monitoring results were received from the laboratory.
EPA reports that high-pressure spray applications may result in some
aerosolization of pathogens, and that application or incorporation of
dewatered biosolids may cause very localized fine particulate/dusty
conditions. Also, farm workers may be exposed to biosolids after
application
and during the restricted period. Ancillary workers, for example
laborers
hired to clean trucks that were used to haul biosolids, can be exposed
to
biosolids. Exposuresto sub-standard biosolids can occur when these
materials
are loaded and hauled to approved landfills or incinerators for
disposal.
Additional study of worker exposures to pathogens and other toxics
possibly
present in Class B biosolids is needed. This will reduce scientific
uncertainty on these issues and allow further refinement of worker
precautions.
What should employers do to prevent work-related illness?
To protect workers who have direct contact with Class B biosolids and
thus
are likely to have an exposure to pathogens, employers should provide a
basic level of protection including appropriate measures from those
listed
below. While the measures are worded to refer to Class B biosolids, most

also apply to tasks involving contact with sewage, untreated or
partially
treated sludge, or sub-standard biosolids.
Provide basic hygiene recommendations for workers.
Basic hygiene precautions are important for workers handling biosolids.
The
following list, originally developed by EPA, provides a good set of
hygiene
recommendations.
1)Wash hands thoroughly with soap and water after contact with
biosolids.
2)Avoid touching face, mouth, eyes, nose, genitalia, or open sores and
cuts
while working with biosolids.
3)Wash your hands before you eat, drink, smoke, and before and after
using
the bathroom.
4)Eat in designated areas away from biosolids handling activities.
5)Do not smoke or chew tobacco or gum while working with biosolids.
6)Use barriers between skin and surfaces exposed to biosolids.
7)Remove excess biosolids from footgear prior to entering a vehicle or a

building.
8)Keep wounds covered with clean, dry bandages.
9)Flush eyes thoroughly, but gently, if biosolids contact eyes.
10)Change into clean work clothing on a daily basis and reserve footgear
for
use at work site or during biosolids transport.
11)Do not wear work clothes home or outside the work environment.
12)Use gloves to prevent skin abrasion.
Additionally, NIOSH recommends the following steps to provide a more
comprehensive set of precautions for use by employers and employees:
Provide appropriate protective equipment, hygiene stations, and training

Personal Protective Equipment (PPE) - Appropriate PPE should be provided
for
all workers likely to have exposure to biosolids. The choices of PPE
include
goggles, splash-proof face shields, respirators, liquid-repellant
coveralls,
and gloves. Face shields should be made available for all jobs where
there
is a potential for exposure to spray or high-pressure leaks, or
aerosolized
biosolids during land application. Management and employee
representatives
should work together to determine which job duties are likely to result
in
this type of exposure, to conduct appropriate on-site monitoring, and to

determine which type of PPE is needed in conjunction with a qualified
health
and safety professional. If respirators are needed, a comprehensive
program
would include respirator fit testing and training or retraining.
Hygiene and Sanitation - Hand-washing stations with clean water and mild

soap should be readily available whenever contact with biosolids occurs.
In
the case of workers in the field, portable sanitation equipment
including
clean water and soap should be provided. Cabs should be wiped down and
cleaned of residual mud (or settled dust) frequently to reduce potential

exposure to biosolids.
Training - Periodic training on standard hygiene practices for biosolids

workers should be conducted by qualified safety and health professionals

that covers issues such as: frequent and routine hand washing (the most
valuable safeguard in preventing infection by agents present in
biosolids),
especially before eating or smoking; the proper use of appropriate PPE,
such
as coveralls, boots, gloves, goggles, respirators, and face shields; the

removal of contaminated PPE and the use of available on-site showers,
lockers, and laundry services; proper storage, cleaning, or disposal of
contaminated PPE; instructions that work clothes and boots should not be

worn home or outside the immediate work environment.
prohibition of eating, drinking, or smoking while working in or around
biosolids. procedures for controlling exposures to chemical agents that
may
be in biosolids.
Reporting - Workers should be trained to report potentially work-related

illnesses or symptoms to the appropriate supervisory or healthcare
staff.
This may aid in the early detection of work-related health effects.
Immunizations - Ensure that all employees are up-to-date on
tetanus-diphtheria immunizations, since employees are at risk of
soil-contaminated injuries. Current CDC recommendations do not support
hepatitis A vaccination for sewage workers.
Extend good environmental practices to prevent and minimize occupational

exposures
Where feasible, substituting Class A biosolids could reduce the pathogen

exposure risks during land application compared to applying Class B
biosolids. Feasibility may be affected by local customer preferences
since
the two types of biosolids vary in the nutrient value they provide to
end-users.
Monitor the source material coming from the wastewater treatment
facility.
Check monitoring results to assure they meet specified Class B or Class
A
standards prior to land application operations.
Monitor stored biosolids prior to application to assure that the
biosolids
are properly stabilized and that unacceptable re-growth or
cross-contamination from sub-standard material has not occurred.
Where local conditions permit, inject biosolids below the soil, or
incorporate (thoroughly mix) into tilled soil. This will minimize
post-application worker contact with applied biosolids and prevent
re-suspension into the air during periods of dryness.
On windy days, avoid spreading or disturbing dry biosolids (e.g.,
compost)
that would create dust.
On windy days, avoid spreading biosolids by high-pressure spray to limit

aerosolization. Avoid unnecessary mechanical disturbance and contact
with
land-applied Class B biosolids during the period when public access is
restricted.
Equip heavy equipment used at storage and application facilities with
sealed
positive pressure, air-conditioned cabs that contain filtered air
recirculation units.
Monitor worker exposures when adjusting precautions to address
site-specific
issues.
For More Information
Additional information about biosolids and preventive measures can be
obtained from the following governmental websites:
Environmental Protection Agency (EPA): Biosolids. Homepage at:
www.epa.gov/owm/bio.htm (The EPA site includes links to professional
associations that address biosolids.)
National Center for Infectious Diseases (NCID). Viral Hepatitis Resource

Center at: www.cdc.gov/ncidod/diseases/hepatitis
National Institute for Occupational Safety and Health (NIOSH): Homepage
at:
www.cdc.gov/niosh
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Thursday, June 13, 2002

U.S. Round 2 Part 503 Sewage Sludge Regulations

Posted to the SludgeWatch List Serv by Maureen Reilly ...
****************************************************

EPA NODA for Round 2 Part 503 Regulations Show Very Low Risks from Dioxin

EPA published in the 6-12-02 Federal Register a notice of data availability for the
Round 2 Part 503 sewage sludge regulations. This document summarizes the new sewage
sludge data and risk assessment for dioxin. Based on a revised risk assessment
(probabilistic) for land application of sewage sludge, the Agency estimates that its
highly exposed population to land-applied sewage sludge using the current cancer
slope factor is very low, ranging from 2 x 10-5 to 1 x 10-6. EPA had proposed a 300
ppt dioxin limit for land application of biosolids in 1999 and is inviting comment on
whether setting such a limit would make no detectable difference in risk or if no
further action or rulemaking should be taken. In addition, the Agency is inviting
comment on whether a voluntary methodology should be used to identify, reduce, and
eliminate sources of dioxin from entering wastewater facilities that contribute to
occasional elevated levels of dioxin in sewage sludge.
In addition, EPA is inviting comment on the effect of applying approaches in EPA's
current Draft Dioxin Reassessment concerning non-cancer health effects of exposure to
dioxins as they relate to land application of sewage sludge. EPA also conducted a
screening analysis of the effects of dioxins in land-applied sewage sludge on
ecological species, which is addressed in this notice. EPA is requesting comments on
the new data and risk analysis, as well as dioxin exposure information, and any
impact that this may have on the proposed rule with respect to land application of
sewage sludge. EPA is under a court-ordered deadline to take final action by 10-17-02
on the proposed land application rule. The deadline was recently extended to October
17, 2003 with respect to land application; EPA met the previous court-ordered
deadline of December 15, 2001 for taking final action on the Round Two proposal
concerning surface disposal and incineration in a sewage sludge incinerator.

There is a list of 12 request for comments that are posted at the end of the Federal
Register notice. Comments on this document must be submitted to EPA in writing and
must be received or postmarked on or before midnight September 10, 2002.

To view the 6-12-02 Federal Register notice, click on ...

http://www.epa.gov/fedrgstr/EPA-WATER/2002/June/Day-12/w14761.pdf