There are several issues regarding the newly
implemented Grand Canyon National Park Service regulation concerning the handling of human
waste on the river that merit discussion.
The primary concern for guides I have spoken with is the greater health risk
resulting from increased handling of fecal matter. Regardless of the various multi-day use
container systems utilized to comply with the new regulation, guides are much more exposed
to open feces and the dangers inherent therein.
Both the Infectious Disease and Occupational Health Service offices at the
University of Utah Health Sciences Canter not only corroborated my concerns about the
health risks, they stressed the necessity for vaccinations against the Hepatitis B virus
for everyone handling human feces. While it was their medical opinion that Hepatitis B
vaccine was imperative for those in direct contact with feces, they also noted that
Hepatitis B is but one of a host of potential health risks. As guides, the increased
exposure to these risks translates directly to increased risks for people we take through
Grand Canyon. The exposure would occur primarily through food preparation, for which most
guides are also responsible.
I would like to enumerate some of the areas of greater contact with human
1. Lids of multi-day use containers often have feces on them. These lids have to be
handled each time the system is set up and torn down.
2. The funnels on certain systems require daily cleaning. The brushes used to clean them
retain fecal matter and/or used toilet paper. The brushes have to be rinsed in water which
in turn has to be dumped somewhere.
3. Emptying said containers is problematic. The Scat Machine at Pearce Ferry has been out
of order more times than not for me thus far. River companies that do not have in-house
Scat Machines must empty feces directly into septic systems. In most cases this involves
pouring the waste into concrete holes or through grates.
4. The containers must then be cleaned. This is done by high pressure water spray, which
can splash back, or by direct brushing.
There have been instances where some commercially available containers leaked
at the drain plug directly into boats. There was another case where one of my co-workers
was splattered with feces that was left in the Scat Machine from a previous user.
Aside from the health risks multi-day use containers pose other problems.
These include the weight of full or partially full tanks, as well as space inefficiency
It is apparent that given all the above, the previous system was much
cleaner, safer and more efficient. I recognize that one of the reasons behind this new
system was to get away from non-biodegradable waste (plastic bags). I concede that this is
a goal we should all work towards. In this case, however, the new multi-day use, reusable
container has created more problems than the one it purportedly solves.
It is my understanding that another reason for the new system was to comply
with the Resource Conservation and Recovery Act, as amended, for all municipal solid
waste landfill (MSWLF) units and the Clean Water Act, for MSWLFs used to dispose of
sewage sludge. In my reading of both amended acts I did not find any reference to the
illegality of disposing human waste in the forms we would generate on river trips at
MSWLFs. (See Federal Register/ Volume 56 No. 196/ Wed. Oct. 9 1991/ Rules and
Regulations/ Subpart A).
This was corroborated by Jerry Allen, Environmental Protection Specialist at
the EPA Regional Office in Denver. He said there is nothing in the new regulations that
make it illegal to dispose of human waste in the forms we see on river trips at
MSWLFs. He added that the decision to accept human waste at MSWLFs is entirely
that of the owner or operating agency with no bearing to legal requirements.
Given all the negative aspects associated with the new system, I would like
to suggest that the option of using the previous system be reinstated until a system can
be devised whereby direct contact with fecal matter is virtually eliminated and we are not
contributing to the burden of non-biodegradable waste at our landfills.
I recognize that there may be river companies that use the new system and
find it workable. I am certain that, given the option, several would prefer to utilize the
old system until the best system is devised.
Any additional comments and suggestion are welcome. Thanks !
Abel O. Nelson