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					Perception Management of Coliform Bacterial Diseases & Biosolids

Perception Management of Coliform Bacterial Diseases & Biosolids
Fecal Coliform is the Name of a Test, Not an Indicator of Pathogens

By Jim Bynum, VP
Help For Sewage Victims
Revised     1/15/2009
Retired Safety Consultant

    Some folks have a firm belief that coliform is some type of bacterial
    indicator and fecal coliform is simply nonpathogenic gut bacteria . Did
    EPA really fool state health officials and state regulators? Coliform and
    fecal coliform, like Biosolids, are simple terms that cover a multitude of
    sins (errors). Cousin Nancy's idea is that we need two new terms for the
    EPA tests, the coliform bucket and fecal coliform dipper. The coliform
    bucket test looks for all of the Enterobacteriaceae family of bacteria
    (saprophytes and plant and animal parasites) that are similar to E. coli,
    ( ferment lactose and produce acid ) and grow at body temperature.
    Optimum growth rate temperatures are between 25°C (77°F) and 40°C
    (104°F). The fecal coliform dipper test looks for the extremely small
    number of thermotolerant bacteria out of the coliform bucket that
    continue to grow after you are dead by 108°F. Why would EPA design a
    test claiming to assure safety of sludge biosolids, food and water, if only
    some minimum number of gram negative bacteria, or none, are found
    growing in the test culture at the elevated temperature of 112-113°F.
    Coliform (relating to, resembling, or being E. coli) is a term for a
    test used to describe the Enterobacteriaceae group of Gram-negative,
    facultative anaerobic rod-shaped bacteria that ferments lactose to
    produce acid and gas within 48 h at 35°C (95°F) , most are now human
    Fecal coliform is a term for a test used by FDA and EPA to describe a
    small number of the same bacteria (primarily thermotolerant E. coli)
    that continue to grow after the internal temperature of the body is raised
    to the point you are dead. They ferment lactose at elevated incubation
    temperatures within 24 hours at 45.5°C (113.9°F) for food testing and at
    44.5°C (112.1°F) for water, sludge, shellfish and shellfish harvest water
    Biosolids is a term used to describe sewage sludge that contained
    less than two million of the same thermotolerant(Primarily E. coli) bacteria
    per gram (most probable number) growing at an elevated temperature of
    44.5°C (112.1°F) within 24 hours in the Fecal coliform test (Class B). The
    pathogen Klebsiella is a similar bacteria.
    Biosolids is also a term used to describe sewage sludge with one
    thousand of the same thermotolerant (Primarily E. coli) bacteria per gram
    growing at elevated temperatures (Class A) when the sludge leaves the
    treatment process. Elevated temperatures and a lack of nutrients at the
    end of the treatment process prevent the culture of the less
    thermotolerant bacteria from showing up in the test, but they may still be

Perception Management of Coliform Bacterial Diseases & Biosolids

   viable bacteria dangerous to public health by contaminating air, food,
   and water. The sins and errors have been compounded by many well
   meaning scientists who do not understand the difference, but that is

Do health officials and regulators know that coliform and fecal coliform are
names of tests rather than normal gut bacteria?

Like most of you, during the better part of 20 years of sludge research by my wife Gail
and I, we assumed there was a true non-pathogenic coliform microorganism. We
believed, because we had never heard of coliform disease. Fourteen years of sludge
exposure gives you a lot of experience and expensive long term health problems.
EPA's position is the general public will never know what a coliform is and that you can
not prove a connection to pollutant contaminated sludge exposure. Nevertheless,
close to $100,000.00 in medical invoices to social security (Medicare) in one year for
two people who have documented exposure to coliform (E. coli and Salmonella)
contaminated sludge might be an indicator that there could be a serious problem.

If EPA had not lied about the nature of coliform there would be no sludge victims and
no sludge use. Can you imagine telling a farmer or home owner that the test results
only indicate a small number of thermotolerant gram negative bacteria species that
managed to survive the high incubation temperature of the test and many will be
pathogens? How could EPA explain why it does not require testing at optimum growth
rate temperatures? How can anyone claim sludge is safe when the test is designed to
ignore the majority of the pathogenic disease microorganisms? Direct exposure is not
the only problem. EPA acknowledges you could be exposed to all forms of the
pathogenic Enterobacteriaceae and other death dealing pollutants in sludge through
the air, food and water. It took a little band of dedicated scientists to develop this

We thought we understood this complex issue when SLUDGE DISPOSAL: Sanitary
Landfill - Open Dump - Superfund Site was published in February 1993. We even
thought we understood the perception issues better with the 1996 book length
Review of National Academy of Science's (NAS) 1996 literary review report by
its National Research Council (NRC) Committee : "Use of Reclaimed Water
and Sludge in Food Crop Production", which was written for the first meeting of
the National Sludge Alliance. This was followed by the National Sludge Alliance
Fact Sheets starting in 1997. We thought we had a good understanding of the
issues and history with the 1998 book Deadly Deceit. On November 16, 2000, The
Pitch Kansas City published part of the story as Field of Bad Dreams by Joe Miller.
The cover story title was "The Waste Land." After Miller explained how complex this
issue is for reporters, we created to pull the sludge
documents and studies together so we could access the information easily. Then was created to document and refine the information
concerning the danger to public health through our food and water. However, like the
reporters, scientists, water quality professionals, sludge experts and politicians we
missed a key point: coliform and fecal coliform are not specific bacteria, they are the

Perception Management of Coliform Bacterial Diseases & Biosolids

names of tests for a class of bacteria that is easy to inactivate by starvation and only
require low levels of heat or disinfectants to become nondetectable.

We assumed EPA would not lie in its publications and never thought much about the
use of the term coliform until Gail was released from a local Hospital with a hospital
acquired Citrobacter urinary tract infection. Citrobacter is one of the coliform bucket of
Enterobacteriaceae pathogens. Gail's doctor did not know it was a coliform, but he did
know the bacteria was very dangerous, Gail was given a 10 day antibiotic treatment
regimen rather than the normal 5 to 7 day treatment for urinary tract infections. After
that I was diagnosed with cerebrovascular disease. The interesting point is that 20
years ago the medical profession was not sophisticated enough to diagnose or repair
the damage. At that time,the best my children could have hoped for would have been
the responsible for caring for an old drooling vegetable. Conventional wisdom and
scientific consensus would have blamed a lifetime of smoking. However, when I
rechecked medical studies for the coliform bucket of bacteria, I found some of them
(such as E. coli) could cause cerebrovascular disease and even empyema (See
Table 1) Cerebrovascular disease was the third leading cause of death in 2005. . For
a broader list of bacteria and diseases see Table 2.

We were truly shocked to find the medically profession could not identify or define a
coliform. For these reasons, I can understand why reporters, doctors, scientists, water
quality professionals, sludge experts and especially politicians might not understand
exactly what constitutes EPA's idea of a coliform or a fecal coliform. EPA only
mentioned three bacteria out of the coliform bucket in the 1989 list of primary
pathogens in sludge, E. coli, Salmonella and Shigella. Currently, conventional wisdom
and scientific consensus concludes coliform is some form of generic soil or vegetation
bacteria and fecal coliform is a non-disease causing indicator organism found in the
human gut. It was/is easy to believe this nonsense, since EPA has gone to a lot of
trouble to educated the public to its way of thinking.

However, in a 2008 published study of coliform in restaurant food, researchers at
Baylor College of Medicine, School of Public Health found "Twenty-five percent of the
Houston samples had an average of 22,000 coliform bacteria per gram of sample" (of
vegetables contaminated with both enterotoxigenic and enteroaggregative toxins from
the coliform bucket: Citrobacter, E. coli, Enterobacter, Klebsiella, Pantoea,
Pseudomonas and Serratia.). The government's scientific consensus is the food is still
safe because the scientists did not test for thermotolerant variants of coliform carrying
enterotoxigenic and enteroaggregative toxins (fecal coliform -- E.coli) which is tested
for at a higher temperature -- where bacteria no longer grow well and you would
already be dead..

The basis of EPA's Perception Management Disinformation Program is to claim
spreading pathogenic bacteria in the environment is perfectly safe as long as the laws
and regulations are followed on the one hand. On the other hand, EPA claims to have
a complete lack of data or even the ability to enforce the laws and regulations. These

Perception Management of Coliform Bacterial Diseases & Biosolids

high paid Ph.D's also claim the right to be dumber than dirt with the statement that
"Coliforms are a group of bacteria, most of which are harmless." However, since
coliform is a made up term like biosolids, it exists only in the minds of a few people at
FDA and EPA, coliform can be defined by FDA and EPA any way they want too with a
straight face. EPA has now taken the pretense of dumbness to a new level with the
call for public comments on what Congress meant by the term solid waste. EPA states,
"The meaning of ``solid waste'' as defined under RCRA is of particular importance
since CAA section 129 states that the term ``solid waste'' shall have the meaning
``established by the Administrator pursuant to [RCRA].''

Congressional wording was straight forward in the RCRA, since the coliform bucket's
infectious characteristics makes sludge a hazardous waste under the RCRA, it is clear
EPA is looking for public comment to tell them how the EPA Administrator may use
exclusions in the law to subvert Congressional intent just as EPA did with the solid
and hazardous waste laws to make sludge a normal application of fertilizer.

EPA's Perception Management disinformation program even confused the writers of
the medical dictionaries. As an example, Dorland's Medical Dictionary defines coliform
bacterium as "one of the facultative gram-negative, rod-shaped bacteria that are
normal inhabitants of the intestinal tract of humans and animals. See: Citrobacter,
Edwardsiella, Enterobacter, Escherichia, Klebsiella, and Serratia." The dictionary also
defines coliform gastroenteritis as though it does not affect humans: "Colliform
gastroenteritis, a diarrheal disease of baby pigs caused by enterotoxigenic strains of
Escherichia coli, marked by profuse, watery diarrhea, dehydration, and acidosis,
frequently leading to death." It also kills new born calves and children.

There is no indication in Dorland's Medical Dictionary that these same bacteria are
part of the "Enterobacteriaceae , a large family of gram-negative, facultatively
anaerobic, rod-shaped bacteria of the order Enterobacteriales, usually motile with
peritrichous flagella, consisting of saprophytes and plant and animal parasites of
worldwide distribution. In humans, disease results from both invasion and production
of toxins. Members of this family are a common cause of nosocomial [hospital
acquired] infection, and species not normally associated with disease may be
opportunistic pathogens. See accompanying table." (of 21 disease causing
microorganisms -- 18 of the disease causing bacteria are included in coliform Table 1)

It started innocent enough according to FDA, "In 1914, the U.S. Public Health Service
adopted the enumeration of coliforms as a more convenient standard of sanitary
significance." "Coliform is not a taxonomic classification but rather a working definition
used to describe a group of Gram-negative, facultative anaerobic rod-shaped
bacteria that ferments lactose to produce acid and gas within 48 h at 35°C." (95°F)
These were the enteric bacteria such as Citrobacter, E. coli, Enterobacter,
Klebsiella, Salmonella, Shigella, and Yersinia.

That is no longer the standard because these bacteria have picked up new virulent
factors as they passed through wastewater treatment plants and the sewage effluent

Perception Management of Coliform Bacterial Diseases & Biosolids

has contaminated surface water. Not only that, but FDA has revised the time and
temperature of the definition of gram-negative bacteria to create a new term for
sanitary significance -- fecal coliform. According to FDA, Fecal coliform is a subset of
total coliforms that grows and ferments lactose at elevated incubation temperature,
hence also referred to as thermotolerant coliforms -- analyses are done at 45.5°C
[113.9°F] for food testing, except for water, shellfish and shellfish harvest water
analyses, which use 44.5°C (112.1°F) .

That is a problem since you would already be dead at that temperature. The second
problem is that most pathogens become non-culturable at that temperature. As D. H.
BERGEY, Laboratory of Hygiene, University of Pennsylvania, noted in 1919, "The
maximum temperature for the pathogenic bacteria is about 45°C [113°F] . Their
optimum temperature is about 37.5° C [99.5°F]." What that means is that 90 years
ago, most bacteria were inactivated at about 45°C and no longer replicated by
standard culture methods. That was also before E. coli picked up the genes to
become the thermotolerant pathogen 0157. That was about 50 years before the
shiga-toxin producing gene that doubles the potential for death was transferred to E.
coli. The potential for kidney failure is well understood. It is not as well understood that
while antibiotic treatment may kill the bacteria, the death of the bacteria creates a
powerful toxin which may kill the patient. This is especially true for E. coli.

A July 2007 study by Ramteke, et al., found antibiotic resistant thermotolerant 04
(Uropathogenic E. coli, UPEC), 025 (Enterotoxigenic E. coli, ETEC), 086
(Enteropathogenic E. coli, EPEC), 0103 (Shiga-toxin producing E. coli, STEC), 0157
(Shiga-toxin producing E. coli, STEC), 08 (Enterotoxigenic E. coli, ETEC) and 0113
(Shiga-toxin producing E. coli, STEC) in drinking water systems. "Transfer of
resistances to drugs and metallic ions was observed in 9 out of 12 strains studied.
Resistances to bacitracin were transferred in all nine strains. Among heavy metals
resistance to As3+ followed by Cr6+ were transferred more frequently. "

For most government agencies, Perception Management of the coliform bucket of
disease organisms is based on raising the test temperature by 9.5 degrees
centigrade (15.1 degree Fahrenheit) to thermotolerant levels for sludge as well as
water and calling the organism fecal coliform when it really means E. coli. That 15.1
degree temperature spread is the difference between testing for Enterobacteriaceae
(coliform bucket) disease causing bacteria at 35°C -- 95° F (Total) for 48 hours or
thermotolerant strains of disease causing bacteria (fecal -E. coli) at (44.5° C --
112.1° F) for 24 hours or less. In both instances, E. coli is the primary bacteria
because it is easy to identify by color in the tests. Not only is replication of bacteria
inhibited by the higher temperature, there are 24 hours less in which the number of E.
coli bacteria would have doubled every 20 minutes.

EPA defines the bacteria in the coliform bucket, "the group is defined as all aerobic
and facultative anaerobic, gram negative, non-spore forming rod-shaped bacteria that
ferment lactose with gas and acid formation within 48 h[ours] at 35°C (95°F) ." "The
fecal coliforms are part of the total coliform group. They are defined as gram-negative

Perception Management of Coliform Bacterial Diseases & Biosolids

nonspore forming rods that ferment lactose in 24 ± 2 hours at 44.5 ± 0.2°C [113.9°
F]" The terms are a little confusing. However, an email to EPA Virologist, Mark
Meckes resolved the issue. Meckes defines the term fecal coliform this way,
"Thermotolerant strains/variants of virtually any of the Enterobacteriaceae would also
be defined as "fecal coliform" as long as they produced acid and gas under the
specified test conditions." There is also a question as to why EPA's enzyme-based
tests suppress Aeromonas spp bacteria which mimics E. coli and is just as deadly?.

EPA implies that thermotolerant fecal coliform (E. coli) has equal growth potential as
coliform (Enterobacteriaceae) and ferments more lactose in 24 hours at 9.5°C higher
temperature. Yet they are the same bacteria and reports show there is always a lower
amount of fecal coliform (E. coli). This may be why coliform Perception Management
gets a little more flaky at the state level. The implication is that the thermotolerant
fecal coliform are found in the intestines of people and animals at a temperature of
44.5°C. It would appear that even the state health and Water Quality Professional
experts assumes you are still going to be alive when your feces reaches 112.1
degrees Fahrenheit. Perhaps they don't understand the metric system. The human
body will die at an internal temperature of 42.5° C. (108.5° F).

The states would also like you to believe there are 3 classes of bacteria tested at the
same time and temperature. In the following example the state implies E. coli is not
part of the Total coliform group. Washington Department of Health -- Division of
Environmental Health -- Office of Drinking Water

Total coliform, fecal coliform, and E. coli are all indicators of drinking water
quality. The total coliform group is a large collection of different kinds of bacteria.
Fecal coliforms are types of total coliform that mostly exist in feces. E. coli is a sub-
group of fecal coliform. When a water sample is sent to a lab, it is tested for total
coliform. If total coliform is present, the sample will also be tested for either fecal
coliform or E. coli, depending on the lab testing method.

Total coliform bacteria are commonly found in the environment (e.g., soil or
vegetation) and are generally harmless. If only total coliform bacteria are detected in
drinking water, the source is probably environmental. Fecal contamination is not likely.
However, if environmental contamination can enter the system, there may also be a
way for pathogens to enter the system. Therefore, it is important to find the source
and resolve the problem.

   There appears to be only one person at EPA, Mark Meckes, who will tell
   the truth: "The total coliform group consists of several genera of
   bacteria belonging to the family Enterobacteriaceae" E. coli is part of
   this family of bacteria.

Fecal coliform bacteria are a sub-group of total coliform bacteria. They appear in
great quantities in the intestines and feces of people and animals. The presence of
fecal coliform in a drinking water sample often indicates recent fecal contamination »
meaning that there is a greater risk that pathogens are present than if only total

Perception Management of Coliform Bacterial Diseases & Biosolids

coliform bacteria is detected.
   According to Meckes, "most strains of Escherichia coli will ferment
   lactose under the elevated temperature test for fecal coliform and
   therefore will meet the definition of "fecal coliform." Similarly, some
   strains of Klebsiella will also ferment lactose under these same test
   conditions and will meet the definition of "fecal coliform".

E. coli is a sub-group of the fecal coliform group. Most E. coli bacteria are harmless
and are found in great quantities in the intestines of people and warm-blooded
animals. Some strains, however, can cause illness. The presence of E. coli in a
drinking water sample almost always indicates recent fecal contamination » meaning
there is a greater risk that pathogens are present.
   Scientists and health officials get blamed for this fuzzy thinking of not
   knowing the difference between the three. Yet, according to Meckes,
   "Most likely this confusion is due to the fact that total and fecal
   coliform are defined by the methods used not the tenets of systematic

Actually E. coli has been genetically manipulated so many times the harmless strains
may be lab strains -- cloned K12. The International Escherichia and Klebsiella Centre
(WHO) has a very large strain collection of approximately 60,000 E. coli strains, most
of which are clinical isolates. This collection includes test and reference strains for O,
K, H and F antigens, various toxins and other E. coli virulence factors. The collection
contains strains representing almost any possible sero- and virulence type.

As a group E. causes inflammatory diarrhea , heart disease, destruction of red blood
cells and kidney failure (hemolytic-uremic syndrome), urinary tract infections,
bacteremia, meningitis, severe lung infection , pneumonia, abscesses in the lining of
the lungs (empyema), necrotizing "flesh eating" infections in the urinary tract and the
abdominal cavity.


In discussing bacterial disease, we need to understand how you might be exposed
through your environment, your air, food, and your water. Historically, we are told that
bacterial diseases are transmitted through direct contact with a sick person, fecal
contaminated food or water or unprotected sexual contact. That doesn't explain the
reality, but from a governmental aspect it places the blame for disease on you. E.
Coli was first proposed as an indicator for fecal contamination in the late part of the
19th century. The reason was E. coli is widely distributed in humans an other warm
blooded animals. It is a major part of the intestinal organisms that keep the body
operating. However, there was a problem, E. coli was part of the family of
Enterobacteriaceae which include known pathogens such as Salmonella, Shigella,
and Yersinia. Other than E. coli genetically engineered to manufacture certain
products, most strains of E. coli are considered to be opportunistic pathogens which
can cause disease in people with a poor immune system, except for those E.coli

Perception Management of Coliform Bacterial Diseases & Biosolids

strains considered to be true (Frank) pathogens, which can cause disease in
anyone. The first E. coli 0157:H7 case (a Naval Officer) documented with samples at
CDC was in Oakland, California in 1975. However, E. coli was still chosen as an
indicator of fecal contamination because it was much easier to detect due of its ability
to ferment glucose (later changed to lactose). There was a small hitch, other
members of the Enterobacteriaceae family such as Citrobacter, Enterobacter and
Klebsiella also ferment lactose and are too similar to E. coli in characteristics to easily
tell them apart.

Currently, we know the optimum temperature for both coliform and other mesophiles --
"Pathogenic micro-organisms that grow best at temperatures between 25°C [77°F]
and 40°C [104°F]." This begs the question, why would government agencies assure
us our food and water are safe based on testing for a small group of easy to
inactivate bacteria that might or might not grow at 44.5°C (112.1°F -- EPA) or 45.5°C
(113.9°F -- FDA) .

Data from the Houston Medical School show the coliform bucket of
Enterobacteriaceae “have earned a reputation placing them among the most
pathogenic and most often encountered organisms in clinical microbiology. They are
the causative agents of such diseases as meningitis, bacillary dysentery, typhoid, and
food poisoning.” Yet, FDA did not appear to understand that E. coli was a pathogen
that did not grow (replicate) well as 45.5°C (113.9°F). On the other hand perhaps
FDA did understand which explains why FDA can not find the source of many
foodborne outbreaks. FDA only mentions Citrobacter, Klebsiella, Enterobacter and E.
coli as coliform. FDA/Center for Food Safety & Applied Nutrition explains why your
food and water are no longer safe:

Although coliforms were easy to detect, their association with fecal contamination was
questionable because some coliforms are found naturally in environmental samples
(6). This led to the introduction of the fecal coliforms as an indicator of contamination.
Fecal coliform, first defined based on the works of Eijkman (12) is a subset of total
coliforms that grows and ferments lactose at elevated incubation temperature, hence
also referred to as thermotolerant coliforms.

Fecal coliform analyses are done at 45.5°C [113.9°F] for food testing, except for
water, shellfish and shellfish harvest water analyses, which use 44.5°C [112.1°F]. The
fecal coliform group consists mostly of E. coli but some other enterics such as
Klebsiella can also ferment lactose at these temperatures and therefore, be
considered as fecal coliforms. The inclusion of Klebsiella spp in the working definition
of fecal coliforms diminished the correlation of this group with fecal contamination. As
a result, E. coli has reemerged as an indicator, partly facilitated by the introduction of
newer methods that can rapidly identify E. coli.

The newer method is that E.col is the only coliform that changes color during a very

Perception Management of Coliform Bacterial Diseases & Biosolids

cheap rapid test, except of 0157:H7, which doesn't show up in the test at all. It does
not ferment lactose. According to O. M. M. Bouvet, et al, Unité des Entérobactéries,
Institut Pasteur, "Unlike other E. coli, isolates of serotype O157:H7 do not ferment d-
sorbitol within 24 h, lack β-glucuronidase activity, and do not grow at 45.5°C" (113.9°

Food Contamination

EPA's sludge policy of the 80s and 1993 regulation had a real impact on the food
supply and water. This was why the high temperature fecal coliform dipper test had to
be implemented.

The real question is why would FDA choose to base the safety of our food on finding
coliform bacteria (E. coli) growing at 45.5°C (113.9° F) which is above the maximum
growth temperature, rather than their optimum growth temperature? The German
Eijkman's 1904 research finding that some coliform survive at a temperature of 45°C
[113°F] doesn't do a lot for the science of food safety. This might explain why food
borne illnesses have exploded from two million in 1986 to seventy-six million in 1999
and no one is sure of what is causing the problem. It could also explain why 10 years
later there is no current public data available on the number of cases of foodborne

FDA may have explained part of the question in an 1999 study Potential for
Infiltration, Survival and Growth Of Human Pathogens within Fruits and Vegetables. It
was reported "Microorganisms have been shown to enter produce through various
pathways available due to the natural structure of certain produce. Bacteria can enter
leaves of plants through the stomata and enter fruit through the stem, stem scar, or
calyx (Charkowski, 1999; Samish and Etinger-Tulczynska, 1963; Samish et al., 1963;
Zhuang et al., 1995). Leben (1972) showed that bacteria can be found in more than
60 percent of the buds of field-grown commodities studied, including red clover,
soybeans, cucumbers, turnips, and grapes. In this same study, large numbers of
bacteria were associated with buds, flowers, and small pods on field soybean plants.
Baldwin and Goodman (1963) found a high percentage of apple buds yielding a
specific plant pathogen in midwinter, which suggested that the buds were infected the
previous growing season. Seo and Frank (1999), using confocal scanning laser
microscopy, showed that lettuce leaves dipped in a suspension of Escherichia coli
O157:H7 absorbed the pathogen through the stomata and cut surfaces on the

Perhaps a change is coming. As an example, in a 2008 published study, Coliform
Contamination of Vegetables Obtained from Popular Restaurants in Guadalajara,
Mexico, and Houston,Texas, Hoonmo L. Koo, et al, Baylor College of Medicine, School
of Public Health, tested cooked food with a temperature of at least 33.9°C (93.02°F)
at the table, incubated overnight at 37C (98.6°F). Forty-two percent of the samples
from Guadalajara had an average of 16,000 coliform bacteria per gram of sample.
Twenty-five percent of the Houston samples had an average of 22,000 coliform

Perception Management of Coliform Bacterial Diseases & Biosolids

bacteria per gram of sample. The study only mentioned a few from the coliform
bucket: Citrobacter, E. coli, Enterobacter, Klebsiella, Pantoea, Pseudomonas and
Serratia. This indicates most peoples immune system works as God intended, until
they run up against genetically modified pathogens.

Coliform bucket testing of Enterobacteriaceae (no matter what temperature) isn't very
helpful in preventing disease. In a 2005 study Etiology of Diarrhea in Young Children
in Denmark: a Case-Control Study, It was reported "Surveillance data indicate that
thermotolerant Campylobacter is the most common bacterial gastrointestinal
pathogen for all ages in Denmark." It seems our government agencies only pick up
useful scientific information from other countries that can used in Perception
Management programs. We don't test for this genetically modified pathogen.

Water Contamination

Water contamination has always been a major problem. Waste water treatment plants
were never designed to kill pathogenic microorganisms. In fact some pathogenic
bacteria are used in the waste treatment process. The theory was that dilution was
the solution for all pollutants released to surface water. That didn't work and EPA has
placed greater restrictions on releasing treated effluent to surface water and oceans.
Today the highly advanced toilet to tap drinking water reclamation treatment plants for
treated effluent still can not remove all pathogens. Now HONOLULU, Hawaii, is being
forced to spend 1.2 billion dollars to upgrade two wastewater treatment plants. New
York state needs $36.2 Billion to upgrade the waste water infrastructure.

Studies indicate wastewater treatment plants have been the source of antibiotic
resistant bacteria released into the environment. Part of this may be due to the drugs
dumped into the treatment plants from homes and hospitals. A major factor appears
to be the concentrated mixture of bacteria and viral macrophage that allows the
transfer of toxic and antibiotic resistant genetic material from one species to another.
These genetically modified bacteria may pass through drinking water treatment plants
if they require a high level of disinfection.

In the 1981 study, Effect of UV light disinfection on antibiotic-resistant coliforms in
wastewater effluents. EPA's Mark Meckes reported "It is evident from this work as
well as from the work of others that antibiotic resistant coliforms are entering the
aquatic environment via treated municipal wastewater effluents." "This work also
points out that there is a significant increase in the percentage of the surviving total
coliform population resistant to tetracycline and chloramphenicol after UV irradiation."

"In a May 2006, Municipal Wastewater Treatment: A Novel Opportunity to Slow the
Proliferation of Antibiotic-Resistant Bacteria, University of Minnesota researchers
published data showing that extremely high numbers of multi-drug resistant bacteria
in effluent (treated water) at high levels are being released into the environment from
highly efficient, award winning, sewage wastewater treatment plants. Researchers
were very concerned when they found extremely fast transfer of the drug resistant

Perception Management of Coliform Bacterial Diseases & Biosolids

gene between bacteria in the treatment plant which confirmed EPA studies from the
80s. They appeared to be somewhat confused because the bacteria taken out of the
treated water were not detectable in sludge."

In a WEF study (2007), The Role of Wastewater Treatment in Protecting Water
Supplies Against Emerging Pathogens, Christopher Crockett, wrote, "Traditionally,
regulators, dischargers, and even water suppliers believed that wastewater discharge
the levels of 200 cfu/100 mL of [thermotolerant] fecal coliforms [E. coli] in wastewater
effluent was sufficient to protect against downstream microbial effects. However,
these beliefs are now being challenged by emerging pathogens that are resistant to
standard water and wastewater treatment processes, exhibit extended survival
periods in the environment, can adversely affect sensitive subpopulations, and
require extremely low doses for human infection. Based on this new information, it is
estimated that discharges of emerging pathogens from conventional wastewater
treatment plants as far as 160 km upstream and cumulative amounts of wastewater
discharge ranging from 2 to 20 ML/d have the potential to reach a water supply intake
in a viable state at significant concentrations that could exceed regulatory limits for
drinking water supplies, increase endemic risk from drinking water, and/or require
additional drinking water treatment."

As an example, in a 2007 study, Serogroups of Escherichia coli from Drinking Water,
Ramteke, et al., reported "Fifty seven isolates of thermotolerant E. coli were
recovered from 188 drinking water sources, 45 (78.9%) were typable of which 15
(26.3%) were pathogenic serotypes. Pathogenic serogroup obtained were 04
(Uropathogenic E. coli, UPEC), 025 (Enterotoxigenic E. coli, ETEC), 086
(Enteropathogenic E. coli, EPEC), 0103 (Shiga-toxin producing E. coli, STEC), 0157
(Shiga-toxin producing E. coli, STEC), 08 (Enterotoxigenic E. coli, ETEC) and 0113
(Shiga-toxin producing E. coli, STEC)."

Even the World Health Organization (WHO) appear to be confused when it comes to
fecal pathogens in swimming pools. They say, "Microorganisms that are used to
assess the microbial quality of swimming pool and similar environments include
heterotrophic plate count – HPC (a general measure of non-specific microbial levels),
faecal indicators (such as thermotolerant coliforms, E. coli), Pseudomonas
aeruginosa, Staphylococcus aureus and Legionella spp. HPC, thermotolerant
coliforms and E. coli are indicators in the strict sense of the definition." It is the WHO
position that only Shigella spp and E. coli 0157 are fecally derived. There is a small
problem, only Shigella will ferment lactose as an indicator coliform.

WHO has a fascinating opinion on the Papillomavirus. WHO acknowledges the virus
can be infectious for years (100s), it can be contacted on feet (plantar wart) by
walking on shower and changing room floors. Who states, "The infection is extremely
common among children and young adults between the ages of 12 and 16." This is
the prime age for contacting Papillomavirus cervical cancer, which now infects over 25
million young women and children. A vaccine for females between ages 9 to 26 years

Perception Management of Coliform Bacterial Diseases & Biosolids

old was approved in 2006. In 2007 sales of the vaccine exceeded $1.5 billion dollars
and the manufacture is looking to market the vaccine for boys. Some viral outbreaks
are documented, yet, WHO declares "Papillomavirus is not transmitted via pool or hot
tub waters." Hum? That appears to be Perception Management issue when you can
get an infection from a wet floor, but not from full contact with water in a bath or while
swimming. It is clear, sexually transmitted does not necessarily mean sex is involved. It
simply means the genital area is where the primary infection occurs.

Waste water and drinking water treatment plants don't do a good job of removing
viruses, which is why they don't test for them. In the 2006 Project: Diversity and
Distribution of Pathogenic Viruses in the Florida Keys , Erin Symonds said, "PCR was
used to detect 10 major viral groups (adenoviruses, herpesviruses, hepatitis B
viruses, morbilliviruses, noroviruses, papillomaviruses, pepper mild mottle viruses,
picobirnaviruses, reoviruses, and rotaviruses) in raw sewage collected from
throughout the United States and from five marine environments ranging in their
proximity to dense human populations."

Sludge/Biosolids Contamination

In North Swanzey, NH -- Victims of sludge composting facility reported skin rashes,
nausea, headaches, watery eyes and respiratory problems --Study found high rates
of cervical cancer between 1987 and 1991, but concluded that the sewer plant could
not have contributed to the increase. Rather,smoking, sex at an early age, multiple
sex partners and a certain virus called human papillomavirus, are known to be linked
to this type of cancer. Hum? True Perception Management, blaming the sexual habits
of small children.

EPA has promoted the use of sewage sludge as a fertilizer on fruits and vegetables
as a policy since the early 80s. Yet, in a 1973 Sludge Use Conference USDA's John
Walker reported to EPA that the coliform Salmonella was not killed by lime treatment
of sludge. About 30 days after sludge treatment the coliform Salmonella was found at
original levels. Walker then joined EPA to run its biosolds Perception Management

In the 1988 EPA study, Occurrence of Pathogens in Distribution and Marketing
Municipal Sludges, Yanko reported "Although the use of sludge as a soil amendment
is attractive, it is not without potential health risks. Toxic chemicals, including heavy
metals and industrial organics, may enter the food chain and present long-term health
risks." Furthermore, "significant increases in bacterial populations, including
salmonellae, occurred during subsequent production of commercial soil amendment
products." "These increases were consistent with a regrowth phenomenon.

But it gets worse. We can not ignore the chemicals. In another 1988 EPA Study --
Trace Organics and lnorganics in Distribution and Marketing Municipal Sludges,
Baird, et al., reported "Efforts to characterize major unknown organic components
were limited to computer comparisons of GC/MS peaks to the NBS mass spectral

Perception Management of Coliform Bacterial Diseases & Biosolids

library. In none of the cases was a tentative identification made." Furthermore, "As a
result, a significant portion of the major peaks were multi-component peaks whose
identities remain completely unknown."

It has been recognized in Germany, at least since D. Strauch published the study
"Survival of pathogenic micro-organisms and parasite in extreta, manure and sewage
sludge" in 1991, that" most pathogenic agents can survive the treatment process" and
the sewage treatment process causes some of the pathogenic disease organisms to
be absorbed or enclosed in faecal particles during the treatment process.
"Therefore," according to Strauch, "sewage sludge is rightly described as a
concentration of pathogens." Strauch reported that two groups of researchers had
found that pathogenic disease organisms will be taken up inside the food crops.

While American scientist use a little different terminology, the same phenomenon has
been noted. "The problem of pathogen detection in sludge, according to EPA's David
Lewis (1998), "is that the sewage treatment process changes the outside crust of the
aggregates [faecal particles] in sludge and only the pathogens on the outside of the
aggregates are measured by standard tests." He says that most of the microbes are
trapped inside the aggregates. When ultrasound was used to break open the
aggregates of sludge the trapped microbes were revealed. In effect, it appears that
the treatment processes hide most of the pathogens rather than destroying them."

The waste industry publication Biocycle reported the existence of mutant strains of
thermotolerant E. coli and Salmonella in 1996. It is interesting that the article indicated
E. coli and Salmonella were not a part of the coliform bucket of Enterobacteriaceae.
according to the article "Pathogen Destruction and Biosolids Composting" in Biocycle
of June of 1996, "There is some evidence that coliforms and Salmonella sp. can
survive prolonged exposure to temperatures of 55 C." They cite a study done by
Droffner and Brinton (1995) using DNA gene probes, where they detected E. coli and
Salmonella sp. in samples collected from an in-vessel composting facility after the first
15 days of active composting at a temperature above 55 C [131°F]. In Table 5-4
Processes to Further Reduce Pathogens in A Plain English Guide to the EPA Part
503 Biosolids Rule, composting time and temperature requirements for within-vessel
composting method was 55 C [131°F] or higher for three days! Droffner and Brinton
found that it took 56 days and 90 days for the densities of Salmonella sp. and E. Coli,
respectively, to decline below the detection limit...These investigators also "cite
evidence of mutant strains of E. coli and Salmonella sp. resistant to thermal
environments in composting." (p. 68)

Since it required 90 days, rather than the EPA's 3 day requirement, for E. coli levels
to decline to Part 503 Class A levels, this would explain why EPA does not require
testing at the time of disposal or use. EPA noted another major problem in its revised
publication (2003) Control of Pathogens and Vector Attractions, Pathogens may live
in soil for up to one year and on plants for up to six months. EPA said, "one concern is
the potential effect of some human pathogens on animals. Enteric viruses can cross
species lines, and animal life, particularly warm blooded animals, can be affected if

Perception Management of Coliform Bacterial Diseases & Biosolids

they are exposed to some of the pathogens found in sewage sludge."

Yet, EPA and the waste industry forced David Lewis out of EPA over the 2002 study,
Interactions of pathogens and irritant chemicals in land-applied sewage sludges
(biosolids), David L Lewis, et al, noted "Affected residents lived within approximately 1
km of land application sites and generally complained of irritation (e.g., skin rashes
and burning of the eyes, throat, and lungs) after exposure to winds blowing from
treated fields. A prevalence of Staphylococcus aureus infections of the skin and
respiratory tract was found. Approximately 1 in 4 of 54 individuals were infected,
including 2 mortalities (septicaemia, pneumonia). This result was consistent with the
prevalence of S. aureus infections accompanying diaper rashes in which the
organism, which is commonly found in the lower human colon, tends to invade irritated
or inflamed tissue." "The 54 individuals surveyed lived near 10 land-application sites
in Alabama, California, Florida, New Hampshire, Ohio, Ontario, Pennsylvania and
Texas. S. aureus is commonly found in the lower human colon and tends to invade
irritated or inflamed

It seems EPA and its partners keep surprising themselves with new studies that find
treatment processes don't work as engineered. In the 2006 study, Reactivation and
growth of non-culturable indicator bacteria in anaerobically digested biosolids after
centrifuge dewatering, Higgins, et al., reported immediately after centrifuge
dewatering anaerobically digested sludges, "the density of E. coli measured by qPCR
could be five orders of magnitude greater than the density measured by standard
culturing methods (SCMs) --".It was assumed this indicated the reactivation of non-
culturable organisms.

However, since these are mesophiles that grow best between 25°C (77 and 40°C
(104°F) and the study was based on continuous flow digestion at 57.7°C (135.86°F)
and two stage batch digestion at 54°C (129.2°F) , it would appear the dewatering
process simple allowed the bacteria time to cool down to a temperature below 44.5°C
(112.1°F) were a few thermotolerant coliform bacteria could resume growth in the
fecal coliform test. Rapid regrowth was noted during sludge cake storage.

This regrowth/reactivation phenomenon from a viable, but nonculturable condition
after treatment puts the neighbors of sludge sites at risk. In a 2007 study Health
Survey of Residents Living Near Farm Fields Permitted to Receive Biosolids, the
authors state, "We observed an association between respiratory, gastrointestinal, and
general symptoms linked with infectious diseases and residence in homes near farm
fields permitted to receive Class B biosolids. Moreover, we found a significant dose-
response relationship for excessive secretion of tears, abdominal bloating, and
dehydration. These findings are in agreement with the findings of Lewis et al., and
studies on wastewater treatment workers. However, they contradict an earlier study
from 3 areas in Ohio, in which researchers reported no significant differences in the
risk of respiratory, gastrointestinal, and general symptoms between sludge-farm
residents and control-farm residents. In the Ohio study, the biosolids application rates

Perception Management of Coliform Bacterial Diseases & Biosolids

were low and thus exposure levels may not have been comparable to those in this

In fact the 1984 Ohio sludge study was never completed. There was also a disclaimer
that the study should not be used for larger acreage, higher disposal rates and where
sludge had higher levels of disease agents. The most troubling aspect of this
Perception Management Program was that the 1996 NRC scientific study referenced
this one limited epidemic study on human exposure to sludge and cited the author
as:" Brown, R.E, and titled, Demonstration of acceptable systems for land disposal of
sewage sludge. Water Engineering Research Lab. EPA 600/Z- 85- 062. Cincinnati,
Ohio: U.S. Environmental Protection Agency." This scientific group of experts had to
know "The Brown paper was a very biased third party two page abstract of the actual
study. The original study noted the World Health Organization (WHO, 1981) reported
a positive association and a cycle of infections of Salmonella from humans to sludge
to animals to humans where cattle grazed on sludge treated pastures." The title of the
study, Municipal Sewage Sludge Application on Ohio Farms: Health Effects.
Dorn, R.C., et al, Environmental Research 38, 332- 335

Studies are not always equal. Like the 2006 Higgins study, the 2008 study, Effect of
total solids on fecal coliform regrowth in anaerobically digested biosolids, Yinan Qia,
et al., reported "Higher total solids (TS) levels of the dewatered biosolids lead to
greater magnitudes of FC [fecal coliform] increase." They found there was partial
regrowth or reactivation in mesophilic anaerobically digested biosolids after
dewatering. However, they noted an increase of 2 orders of magnitude after
incubation at both 25°C (77°F) and 37 °C (98.5°F). The levels of coliform continued
to increase for 5 days. By day 20, coliform levels were still 2 orders of magnitude
higher than original levels.

In the 2008 aerosol study, A Survey of Wastewater Indicators and Human Pathogen
Genomes in Biosolids Produced by Class A and Class B Stabilization Treatments,
EMILY VIAU, et al., report "Indicator concentrations for fecal coliforms [E. coli] and
male-specific coliphages, as well as pathogen genome concentrations for human
adenovirus spp., Legionella pneumophila, Staphylococcus aureus, and Clostridium
difficile were significantly lower in Class A samples--" "Human adenovirus genomes
were found in 88% of Class B and 70 – 100% of Class A samples. L. pneumophila, S.
aureus, and C. difficile genomes were detected at the qPCR assay detection limits in
19-50% of Class B and Class A anaerobic digestion samples, while L. pneumophila
was detected in 50% of Class A compost samples."

Recently, several Adenoviruses, especially Adenovirus 36 (AD-36) have been shown
to cause Obesity in animals, and association with human Obesity.


Without the coliform bucket and fecal coliform dipper to hide the truth, EPA's sludge
dumping Perception Management Program would have never seen the light of day. In

Perception Management of Coliform Bacterial Diseases & Biosolids

the 70s and 80s the sludge experts found the treatment processes did not destroy
pathogenic bacteria and even created antibiotic resistant bacteria as they passed
through wastewater treatment plants. Since there was no way to effectively protect
surface water and drinking water from sewage effluent, it seemed a reasonable policy
to find the cheapest method of testing and disposal for waste products from the
treatment plant. The sins and errors have been compounded. The end result is that
good bacteria have evolved into killers and that is reflected in explosive levels of
pandemics/epidemics caused by pathogens and toxic chemicals disposed of in the
environment. The only way to fool the public was to raise the temperature of the test
from 35°C (95°F) to 44.5°C (112.1°F) where growth of these bacteria are inhibited.
The Perception Management Program was effective in fooling some scientists,
regulators, politicians and farmers until it started costing to much money and to many
lives. Fortunately, science has advanced to the point where the Perception
Management Program can no longer hide the truth about contaminated water and
food. Scientists may not understand the fine points of the governments Perception
Management Program or the medical danger, but they are starting to publish real
factual studies concerning real bacteria and viruses in an effort to alert the public.

Additional Disease Tables


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