Where have all the scientists gone?
                        Colform testing fraud
What reporters don't know about coliform can hurt you!

By Jim Bynum                                                                                                      7-7-07  
Retired Safety Consultant

California has some of the toughest water laws in the
nation to protect its surface water.  Yet, it has some of
the most sewage contaminated waters. A sewage treatment
plant’s treated effluent may be too contaminated to be
released to surface waters during the dry season, or placed
in a permitted landfill, based on a commercial laboratory test.
However, sewage plant personnel can do a simple coliform
test and release the effluent as reclaimed water or biosolids
for use on food crops, school yards, public parks, industrial
space as well as home lawns.

UC Irvine researcher, Ryan Dwight, estimates  $3.3 million in cost for “74,000 incidents of
stomach illness, respiratory disease and eye, ear and skin infections caused by exposure to the
polluted waters in a typical year.” “researchers estimate that if bacteria levels in these coastal
waters were exactly at accepted levels, the total health cost would be greater than $7 million per

The U.S.Department of Health and Humans Services (HHS) adopted the Enterobacteriaceae family
(coliform) in 1914 as an indicator for fecal waste in food and water. The political, scientific,
medical, and water professional  community seems to have developed Alzheimer's disease  in
1989 when coliform was chosen as an indicator to prove the lack of disease organisms in sewage
effluents (reclaimed water -- sludge/biosolids). Just as in Alzheimer's, slowly the EPA webpages
are deleted one by one and finally, the library is closed and we get

However, all was not lost. Data from the Houston Medical School show coliform “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.” The
12 deadly human pathogens involved are:
Escherichia coli, Enterobacter, Salmonella,  Shigella, Yesinia (Black Plague) and the lesser known,
Edwardsiella, Citrobacter, Klebsiella, , Serratia, Proteus, Morganella, and Providencia.

EPA has made a little joke about its criminal activity of exposing public health to these disease
organisms: “When the news media announce a "boil water emergency," reporters often speak of a
"total coliform violation." Coliforms are a group of bacteria,
most of which are harmless. At first
it might seem strange that a harmless group of bacteria such as coliforms could cause
such commotion.
But like police tape and chalk outlines, coliform bacteria are often found at the
scene of a crime even though they are not themselves criminals.”

EPA even admits the bacteria are injured during the treatment process, and show
up at the scene of the crime: “Total coliforms are a group of closely related bacteria that are (with
few exceptions) not harmful to humans. Because total coliforms are common inhabitants of
ambient water and may be injured by environmental stresses (e.g., lack of nutrients) and water
treatment (e.g., chlorine disinfection) in a manner similar to most bacterial pathogens and many
viral enteric pathogens." They become
viable, but nonculturable.

Recycling a valuable resource is the public relations theme behind the use of chemical and disease
contaminated sewage effluents. The private scheme behind recycling sewage effluents is money
and water.  
Sewage treatment plants needing repair to comply with current rules on releasing
sewage effluent to surface waters will cost billions of dollars. However, as reclaimed effluent, that
same sewage effluent is worth billions of dollars to municipalities.

Agricultural interests are currently allocated 80 percent of the imported water at about 15 dollars
an acre foot. Municipal interest have to make do with the other 20 percent of the water, which
they sell for about 431 dollars an acre foot (2001). Profit wise, building sewage treatment plants
specifically to furnish reclaimed water to agricultural interests  makes sense for municipalities.
The reclaimed sewage effluent can be sold for almost the same price is clean water.

Recycling sewage effluents sounds like a good idea, but it is a scheme gone seriously wrong. In a
letter to John Stauber, author of
1995, J. Patrick Nicholson, Chief Executive Officer of N-VIRO, a sludge fertilizer manufacturer,
summed up the potential problems for POTWs and their managers, "Today, there is no
enforcement and public owned treatment works and their managers are facing severe liability,
including criminal liability."

That is serious charge that was left dangling in the wind for 12 years until
 Dr. Edo McGown,
medical and water specialist, ask the right question.  He said, “I had ask a series of state licensing
and other authorities that might deal with sewage sludge including the various trades associations
that tutor sewer plant operators, and those that make tests as well as supply info for such tests as
taken by sewer plant operators----if there were anything related to
genetic movement, antibiotic
resistance, or infectious disease. From each source the answer was no. Thus sewer plant
operators are in no way proficient or evenly in a rudimentary way prepared to discuss these
issues. Nonetheless, when city administrators seek information, these sewer staff members seem
to feel qualified to pontificate upon these matters----blind leading the blind----or fools rush in
where fools have been before.”

As example, the
city of Santa Barbara sued Tsukamoto Sogyo Company, Ltd., for using city
drinking water to irrigate the Montecito Country Club when reclaimed sewage effluent meeting
state Title 22 requirements was available at about the same price. The city won and the public was
put at risk.

State requirements do not address
viruses.  In Arizona where reclaimed sewage is used on golf
courses,  “The Maricopa County Medical Examiner's Office has confirmed that a 15-year-old
golfer died after contracting the Norwalk virus that sickened 82 other golfers during a tournament
at the Thunderbirds Golf Course.”  The death law suit was settled for 3 million dollars.  

In discussing the benefits of recycled sewage effluent for school yards and buildings, Jim
Graham, Las Virgenes MWD, said, “Since schools have no capital funds available, we developed a
painless conversion financing, in which they would pay potable [drinking] water rates until they
paid back our loan. “

The selling point for reclaimed sewage effluent according to
Earle Hartling, Recycling
Coordinator, L.A. County Sanitation District is, “You don’t have to say the water is dangerous,
you just have to say  “Don’t drink this water,“ and mark the pipes in

This sales pitch apparently works. As Frank Pecarich pointed out in his October 13, 2006, article,
Monterey Cover-up on Cause of Spinach and Lettuce Contamination?
He said, “Monterey County officials stand to be in big trouble if this spinach and lettuce disaster
continues to get more "light of  day". They talked farmers whose farms are located in the
Castroville Sea Water Intrusion Project area into using tertiary treated sewage effluent [Title 22
reclaimed water] to irrigate 12,000 acres of high quality vegetables including leafy green spinach
and lettuce.“

Over 200 people were hospitalized and 3 died from eating the
experimental Shiga toxin-
producing E. coli 0157:H7 contaminated vegetables traced back to the Salinas Valley area.  The
reality is we will never know how many people were infected because the focus was only on one
of the 200 strains of Shiga toxin-producing E. coli. Antibiotic treatment of  for Shiga toxin-
producing E. coli, may kill the patient.

The primary investigation focused on wild animal manure and nearby cattle.   The investigation
was inconclusive. That was to be expected when you consider the top dog behind this
investigation was Mike Leavitt,
U.S. Department of Health and Human Services (HHS), and
boss of the FDA and CDC.  Leavitt is the former boss of the EPA which allowed this to happen.
As a side note,  an Oakland, California  naval officer was the first document case in 1975, yet,a
USDA investigation in 1982 did not find 0157:H7 in any cattle in the United States.

It all starts to make sense. HHS adopted the simple colifom test in 1914 to indicate the presence of
fecal contamination in food and water. Coliform is not a taxonomic classification but rather a
working definition used to describe a family of 12 Gram-negative, facultative anaerobic rod-
shaped bacteria that ferments lactose to produce acid and gas within 48 h at 35°C.

According to Canadian  sources, this group is widely distributed in nature, and many derives its
nourishment from dead or decaying organic matter, in addition to being associated with the
intestinal tract of most animals.  A sub group of total coliforms are called fecal coliforms, and are
defined by their ability to ferment lactose at elevated incubation temperatures in a 24 hour period.
Fecal coliforms are primarily Escherichia coli, although Klebsiella pneumoniae can occasionally
grow at 44.5°C

In the Journal of Water and Health , Vol 5 No 2 pp 267–282, 2007, University of Wisconsin-
Madison researchers compared the 10 EPA approved test methods for
coliform/E. coli and their ability to suppress non-target organisms that could give a false positive
such as Aeromonas spp. Even though the researchers shortcut the study by only using “five
different total coliform organisms (Serratia, Citrobacter, Enterobacter, E. coli, & Klebsiella)”, they
found “wide variability exists among USEPA approved tests to detect and quantify total coliforms,
as well as suppress Aeromonas spp.”

Yes, the tests actually suppress
Aeromonas, a bacteria  capable of causing illness in fish and
amphibians as well as in humans who may acquire infections through open wounds or by
ingestion of a sufficient number of the organisms in food or water. It may cause
enteritis in
anyone or
septicemia in immunocompromised persons or those with malignancies. The
infectious dose of this organism is unknown, but SCUBA divers who have ingested small amounts
of water have become ill.  

On May 1, 1988, isolates of Aeromonas became reportable in California, the first state to mandate
reporting of isolates of and infections with these organisms. From May 1, 1988, through April 30,
1989, clinicians and clinical laboratories in California reported 225 Aeromonas isolates from 219

The El Dorado, County, California ENVIRONMENTAL HEALTH shortcuts both types of
coliform tests. The 48 hour test is cut to 24 hours. The elevated temperature 24 hour test is cut
from 45 to 35 degrees C.. The County Laboratory uses the Colilert  presence/absence method.
This method combines two separate examinations. First, the 100 milliliter sample is combined
with growth medium, and then incubated for 24 hours at 35.0 degrees Centigrade. After 24 hours,
only coliform bacteria will use the growth medium for food, resulting in a change in the water
sample's appearance."

Study shortcuts, test shortcuts, half truths,  and outright lies abound in the wastewater industry.
In drinking water, a positive coliform test indicates fecal contamination from animals or sewage.  
In reclaimed sewage effluent, a low or negative coliform test that could prove its safety would be
a miracle. Yet the politicians, wastewater industry experts and state  health experts look you in the
eye with a grin and state:

State of Kentucky: Total coliform bacteria are a collection of relatively harmless
that live in large numbers in  the intestines of man and warm- and cold-blooded

Washington State Department of Health: Coliform bacteria are organisms that are present in
the environment and in the feces of all warm-blooded  animals and humans.
Coliform bacteria will
not likely cause illness.

Canada: Total coliforms are chosen as indicators of water quality because, although they are not
usually pathogens themselves
, they will be present and recoverable in septic discharges for longer
periods of time than are pathogenic organisms.

CALIFORNIA TITLE 22 Section 64655(b).: “Total coliforms serve as a generic indicator
organism that captures a broad range of potential bacteriological contamination. Fecal coliform
and E. coli are
indicators of specific fecal or human waste contamination.”

Now, June 29, 2007, EPA wants to form a
Total Coliform Rule Distribution System Advisory
Committee. EPA would like the Committee to evaluate available data and research on aspects of
distribution systems
[bacterial biofilms] that may create risks to public health and consider how
to address the risks. But, EPA will not define a coliform.

Jim Bynum is a retired safety consultant. He served on the 1970s Kansas City, Missouri committee to evaluate
methods of solid waste disposal, he is a DOT qualified 49 CFR Parts 100-185 trainer and is a ASME certified
Hyrdogen Sulfide Safety instructor. He serves as an officer of Help For Sewage Victims, since 1992, and served as
research writer for the
National Sludge Alliance.

.  Tell your story in a letter.                              Comments to author
Published in the California Progress Report