You are hereFecal Coliform Test Puts Public Health at Risk: Sludge -- biosolids -- food -- water
Submitted by nimda on Wed, 05/27/2009 - 23:40
Jim Bynum, VP, & Gail M. Bynum, Ph.D Neither the fecal coliform test nor any laws (Solid Waste, Hazardous Waste, Clean Water) protect farmers and the public who are not being told the truth about sludge contaminated with pathogenic microorganisms. Sludge is: 1) a solid waste; 2) a hazardous waste because of E. coli and other pathogens; and 3) a point source pollutant. The current use of the fecal colifom test itself is designed to inhibit the bacterial growth so as to reduce the number of viable but culturable E. coli to less than one percent of the total. It eliminates most indicator E. coli in the sludge sample by making them viable but nonculturable by standard culture methods. This allows unknown amounts of anitbiotic resistant pathogenic superbugs to be spread on farms, parks, school grounds and even home lawns. This practice violates any government regulation for work place safety, especially laboratory safety rules. In June 2006, EPA released the laboratory protocol , Method 1681: Fecal Coliforms in Sewage Sludge (Biosolids) by Multiple-Tube Fermentation using A-1 medium. EPA listed the following laboratory biosafety level 2 practices which must be followed to protect the workers handling and spreading sludge: * The analyst must observe normal safety procedures required in a microbiology laboratory while preparing, using, and disposing of media, cultures, reagents, and materials, and while operating sterilization equipment. Method 1681 is a 51 page document full of charts, graphs and mathematical formulas used to estimate the probable number of heat inhibited E. coli that could be found if the sludge was This is also reflect in the number of foodborne illnesses which exploded from 2 million in 1986 to 81 million case in 1997. In 1998 CDC estimated there were 360 million cases of acute diarrhea, most from unknown sources of exposure. CDC's estimate for foodborne illness was dropped to 76 million in 1999 after the Monterey Regional Water Pollution Control Agency (MRWPCA) and the Monterey County Water Resources Agency (MCWR partnership completed a $78 million project to irrigate 12,000 acres of California's best spinach and lettuce crop land in the Salinas Valley with "reclaimed" sewage water. No new numbers for foodborne illnesses have been released for the past 10 years. However, the publicized outbreaks of foodborne illnesses attributed to contaminated Salinas Valley vegetables have increased. The Fecal coliform Test The safety of sewage sludge and reclaimed water used on farms, parks, school grounds, home lawns and gardens is based on a 105 year old elevated temperature test to detect thermotolerant forms of E. coli in food and water, presumed to be of human fecal origin. The fecal coliform fermentation test requires wastewater treatment plants to incubate the sludge sample at 44.5° C. (112.1° F) for 24 hours. According to EPA. "These [test] methods (1681) use culture-specific media and elevated temperature to isolate and enumerate fecal coliform organisms." Furthermore, "The predominant fecal coliform is E. coli." In his 1904 elevated temperature test for detection of fecal contamination in food and water, Christiaan Eijkman found that elevated temperatures did not kill coli bacilli (Escherichia coli). However, he found the elevated temperature did either reduce or eliminate growth in similar types of coli. He assumed therefore thermotolerant E. coli was from warm blooded animals only and all other coli like bacteria (Enterobacteriaceae) were from cold blooded animals. One hundred and five years later scientists have established that E. coli is the lead pathogen of the Enterobacteriaceae (coliform) family of human, animal, soil and water bacteria of which many are pathogens. Human pathogens grow best at the optimum temperature of 35-37°C (95-99°F). At this optimum temperature, with proper nutrients, E. coli doubles every 20 minutes. Therefore, in 3 hours and 20 minutes, one (1) E. coli colony forming bacteria doubling every 20 minutes would exceed the Class A requirements of 1,000 E. coli per gram by 24 bacteria. Four hours and 40 minutes later the Class B requirements of 2 million E. coli per gram would also be According to preamble to part 503, "EPA concluded that the use of fecal coliform is sufficient to indicate the presence of pathogenic organisms in sewage sludge." "Fecal coliform was selected for the final part 503 regulation because an analytical method exists for fecal coliform and because treatment works conduct fecal coliform analysis routinely." (FR, 58, vol. 32, p. 9348) In 2007 email, EPA's Mark Meckes states that "The fecal coliform group is a subset of the total coliform and it is also defined by the method used for detection. These are facultative anaerobic, gram-negative, non-spore-forming, rod-shaped bacteria that ferment lactose (specifically EC medium) with gas and acid formation within 24 hour at 44.5 degrees C." The key words are EC medium. EC specifically refers to a culture medium used to detect E. coli. According to Perry and Hajna's study Further Evaluation of EC Medium for the Isolation of Coliform Bacteria and Eschericbia coli, (1944), EC medium was developed for the isolation of coliform bacteria at 37°C and of Escherichia coli at 45.5°C. They say, "EC medium was found highly specific for Escherichia coli at this temperature." However, for type II E. coli, the test was only specific for 21.8% of the cultures. In the 1958 study The Coliform Group II. Reactions in EC Medium at 45° C Geldreich, et al., said, "There were 5794 cultures of coliform bacteria from untreated surface water supplies of 14 treatment plants examined. Of the 1358 E. coli included, 83.7 per cent showed positive EC reactions. When the E. coli strains are subdivided into varieties I and II (see table 1), the percentage of positive E. coli 0157:H7 does not show a positive reaction in the test, yet produces a deadly shiga toxin gene (STEC ) which first appeared in a Central America Shigella outbreak. In a retroactive study, Importation of Shiga Bacillus Dysentery Into California, researchers S. BENSON WERNER, M.D., RONALD R. ROBERTO, M.D., AND JAMES CHIN, M.D., Berkeley, identified 20 The first E. coli 0157:H7 case (a Naval Officer) documented with samples at CDC was in Oakland, California in 1975. The next appearance was when it was determined that E. coli 0157: Early scientists first acknowledged the problem with the fecal coliform test in a 1963 Public Health Service Report, SANITARY SIGNIFICANCE OF COLIFORM AND FECAL COLIFORM ORGANISMS IN SURFACE WATER, "Because no satisfactory method is currently available for differentiating fecal coliform organisms from human and other animal origin, it is necessary to consider all fecal coliform organisms as indicative of dangerous contamination." Yet, Knowing that the test temperature inhibits E. coli growth, in 2002, FDA's Bacteriological Analytical Manual Online shows an increased temperature analysis from 35-37°C (95-99°F) to 45.5°C (113.9°F) for food testing and 44.5°C." (112.1°F) for water, shellfish and shellfish harvest water analyses This test was re-designated fecal coliform. According to Ron et al, in there study Growth Rate of Escherichia coli at Elevated Temperatures: Reversible Inhibition of Homoserine Trans-Succinylase (1971), "The preceding paper [Ron, et al.1970] showed that the growth of Escherichia coli is slowed, without killing, at 40 to 45 C, and that in the several strains tested the cause is a decrease in the activity of homoserine trans-succinylase. These temperatures are now shown to inhibit the enzyme directly, in crude extracts and after partial purification. The effect is rapid and is immediately reversible, unlike the progressive and slowly reversible changes of conventional denaturation." In 1974 when Gerald Berg, Chief, Biological Methods Branch of the EPA's National Environmental Research Center in Cincinnati, Ohio warned of the inadequacy of the fecal coliform test, even though he implied pathogenic strains of E. coli were not part of fecal coliform. He stated: "For some time we have been aware that fecal coliforms are not always reliable indicators for viruses and that neither fecal coliforms nor other bacteria are inviolate indicators of fecal pollution. To be sure, fecal coliforms indicate a sanitary hazard, but certain other bacteria may seem to be fecal coliforms in the standard membrane filter test. Moreover, fecal coliform may multiply in waters where pathogenic bacteria and certainly viruses cannot. And fecal coliforms may be destroyed in waters polluted with certain industrial wastes -- wastes that do not seem to affect fecal streptococci and may not affect viruses either. Clearly, it is a matter of some importance to develop a bacterial indicator system that can definitively differentiate fecal organisms from free-living forms. (p. xii)" According to Merck's Fact Sheet, "Lactose-positive bacteria produce yellow-orange colonies and under the membrane yellow halos. The count of these typical colonies is considered to be E. coli does not die quickly or easily. It may not die at all but be in a dormant state as in stationary phase death and heat-shock response. According to A. Eisenstark, et al, Cancer According to Fritz Schöffl, et al, Universität Tübingen, (1999), "The heat-shock response is a conserved reaction of cells and organisms to elevated temperatures (heat shock or heat stress). Whereas severe heat stress leads to cellular damage and cell death, sublethal doses of heat stress induce a cellular response, the heat-shock response, which (a) protects cells and organisms from severe damage, (b) allows resumption of normal cellular and physiological activities, and (c) leads to a higher level of thermotolerance." In the paper, Viable but non-culturable bacteria: their impact on public health, (2005) Yogita N. Sardessai,Goa College of Pharmacy, states the problem: "Viable but nonculturable "(VBNC) bacteria are a major concern in public health risk assessments because many pathogenic bacteria like Vibrio cholerae, Mycobacterium tuberculosis, Campylobacter jejuni, Helicobacter pylori, Vibrio vulnificus and Escherichia coli have been reported to enter a VBNC state from which they are able to return to the "The implications of bacteria to lie in a dormant undetected state are far reaching. For instance, antibiotic resistant chronic otitis medium was earlier considered a sterile James D. Oliver, Department of Biology, University of North Carolina at Charlotte, 2005, said, "It had long been assumed that a bacterial cell was dead when it was no longer able to grow on routine culture media." However, "Since the original 1982 paper from the laboratory of Rita Colwell (Xu et al., 1982), over 400 papers have appeared which describe various aspects of the phenomenon most commonly referred to as the " but nonculturable (VBNC) state" A great many pathogens, as well as nonpathogens, are now known to enter this dormancy state, and its significance in medicine, bioremediation, the use of bacteria as fecal indicators, and indeed in most microbiological studies where culturability is employed as the (often sole) indicator of viability, is becoming increasingly evident." Moreover, "a number of studies have found that Even EPA documents confirm that while heat and chemicals will cause the bacteria to be inactivated, it is a temporary condition. EPA states in (Part 403.5(b)(5)) that "Heat above 40 °C (104 °F) and disinfectants will slow or eliminate biological activity causing some bacteria to become viable, but nonculturable by standard culture methods" In effect, the test itself slows the growth of E. coli and eliminates the growth of the other Enterobacterriaceae family causing them At the same time it ignores the following pathogenic families: 1) Aerobic Gram-Positive Cocci; 2) Aerobic Gram-Negative Cocci; 3) Aerobic Gram-Positive Bacilli; 4) Aerobic Gram-Negative Bacilli: Nonenterobacteriaceae—Fermentative; 5) Aerobic Gram-Negative Bacilli: Nonenterobacteriaceae—Nonfermentative; 6) Aerobic Gram-Negative Fastidious Coccobacilli; 7) Mycoplasma (Pleuropneumonia-Like Organisms [PPLO]); and 8) Treponemataceae (Spiral Organisms). These families of bacteria contain the most deadly community acquired superbugs. Among these are the Invasive group A streptococcal, Staphylococcus, MRSA, Clostridium, most In a February 2009, e-mail EPA's Richard Reding, Chief, Engineering and Analytical Support Branch, pointed out that the heat inactivation of most E. coli and reduction or eliminating other similar bacteria from the test was by design when he wrote that fecal coliform "are distinguished from the coliform group by their ability to grow at the elevated temperature of 44.5°C. Thus, "inactivation" is by design so as to eliminate those bacteria that are unable to grow at 44.5°C According to a July 2007 study, the fecal coliform test would specifically reveal, with the exception of 0157, some heat inhibited thermotolerant E. coli strains. Strains growing in drinking water systems at elevated temperature were, 1) 04 Uropathogenic E. coli,UPEC); 2) 025 Enterotoxigenic E. coli, ETEC); 3) 086 (Enteropathogenic E. coli, EPEC); 4) 0103 (Shiga-toxin producing E. coli, STEC); 5) 0157 Shiga-toxin producing E. coli, STEC); 6) 08 Enterotoxigenic E. coli, ETEC); and 7) 0113 Shiga-toxin producing E. coli, STEC). CDC documents indicate the infective dose for E. coli is estimated to be only 10-100 non-heat stressed organisms. E. coli doubles every 20 minutes, which means that if you are infected with only one bacteria, in 2 hours you are well past the infection stage. Other non-0157 serotypes of E coli –eg O29, O39, O145 produce shiga-like toxins, causing bloody inflammatory diarrhea, evoking Hemolytic uremic syndrome (HUS). According to the According to Meridian Bioscience, STEC infections are very serious because: 1) Antibiotics increase Shiga toxin release and production and should be avoided: 2) HUS [Hemolytic uremic The reality is that the only thing the fecal coliform test proves is that there are an unknown quantity of viable pathogens in sludge. While there may be some non-pathogenic strains, the International Escherichia and Klebsiella Centre (WHO) has a collection of approximately 60,000 E. coli strains, most of which are clinical isolates. No one has any idea how many or what type of unknown and viable but nonculturable pathogens are in sludge and reclaimed water when the test sample is drawn, much less after the test is completed due to the elevated temperature of the test. The number of these thermotolerant E. coli strains that survive the heat and react to EC medium (two million CFU per gram (0.035273 oz) Most Probable Number (MPN) dry weight - Using this outdated test proponents of sludge use claim it proves sewage sludge is safe for use as a fertilizer on food crops, school grounds and your lawn if only a few bacteria are found. The problem is that the elevated temperature test itself inhibits or stops the growth of bacteria in the sample, while the pathogens in the original material continue to thrive at normal temperatures. This test does not offer any protection from contamination of our air, food supply, drinking water, or health as part 503 only discusses pathogen reduction, not elimination. This is Bacteria do not die just because sludge has been treated. In the study Occurrence of Pathogens in Distribution and Marketing Municipal Sludges (1988) William A. Yanko, County Treatment causes some of the pathogenic disease organisms to be absorbed or enclosed in fecal particles during the treatment process. These are biofilms holding the particles together. For this reason, In the study "Survival of pathogenic micro-organisms and parasite in extreta, manure and sewage sludge" (1991) D. Strauch, Institute of Animal Medicine and Hygiene, University of Hohenhiem, warned, "the agricultural utilization of hygienically dubious sewage sludge poses a risk for the whole national economy." After reviewing the sludge rule and laboratory reports from our farm, EPA's own David Lewis warned about the danger to public health from bacterial survival on farms in the article Sludge Magic at the EPA (1999). He said, "the Sludge Rule on land application of municipal wastes (40 CFR Part 503) promulgated in 1993 may be the most scientifically unsound action ever taken by the agency. Rather than being protective, the rule actually threatens public health and the environment." Lewis et al, documented the danger to public health from microorganisms in the study, Interactions of pathogens and irritant chemicals in land-applied sewage sludges (biosolids) A 2007 epidemiologic self reporting survey of neighbors near an Ohio biosolids (sludge) site by researchers from the University of Toledo revealed excessive health problems. The Health Survey of Residents Living Near Farm Fields Permitted to Receive Biosolids (2007), Sadik Khuder, PhD; Sheryl A. Milz, PhD; Michael Bisesi, PhD; Robert Vincent, PhD; Wendy McNulty, MS; Kevin Czajkowski, PhD, found that the, "Results revealed that some reported health-related symptoms were statistically significantly elevated among the exposed residents, including excessive secretion of tears, abdominal bloating, jaundice, skin ulcer, dehydration, weight loss, Conclusion The fecal coliform test that is used as an indicator for fecal contamination of food and water does not protect the farmers and the general public from deadly bacteria, viruses, worms, Farms and associated business are damaged or destroyed, surface and ground water are contaminated, animals and people are sick, dead and/or dying based on a 105 year old test |