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 feces:

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 packing them.

   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 MSWLF’s 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 MSWLF’s. (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 MSWLF’s. He added that the decision to accept human waste at MSWLF’s 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