45.5° C  -- 113.9° F  ----------------- FDA food fecal coliform test -- Enterobacteriaceae -- E. coli, etc.
44.5° C -- 112.1° F ------------------  EPA & FDA (1904) fecal coliform test -shellfish - Enterobacteriaceae -- E. coli, etc
42.5° C -- 108.5° F ------------------  Human blood coagulates at internal temperature -- you die

40° C ---   104° F --------------------  Maximum
optimum growth temperature for Mesophilic pathogens, E. coli, etc

37° C --     98.6° F ------------------- Normal human body temperature --
Hospital lab tests for Mesophilic pathogens
35° C --     95° F   -------------------- FDA -- (1914) coliform Test (food & water) -- Enterobacteriaceae -- E. coli, etc.

25° C --     77° F ---------------------- Minimum
optimum growth temperature for Mesophilic pathogens, E. coli, etc.

(-) 17.77°C  --   0° F
                                                        THE LOFTUS CHART
Do you wonder why government agencies can not find infectious organisms in biosolids, water & food?
They don't test at optimum growth temperature and assume E. coli is not a disease causing organism.
                                                                                                                                       Revised  2/16/2009
By Jim Bynum, VP
Help for Sewage Victims                                  
EPA Press Release 2/13/2009
Retired Safety Consultant                               Excess Pathogens in sludge applied to farms

I recently mentioned laboratory reports showing 8,000 E. coli (with only 30 fecal coliform) per gram of soil contaminated
by runoff from Kansas City, Missouri's sludge farm dump site. A sludge industry laboratory expert immediately tried to
make me look like an uneducated idiot incapable of doing research and challenged those numbers with the statement
in bold red letters: "
"E. coli does not survive for a long time in the environment."  

Rather than trying to embarrass him, I will refer you to The Loftus Chart below which shows why there is a dramatic
difference in the numbers. I have also included a 1980 study which supports the difference. While E. coli is a part of the
fecal group, one is a low temperature test and the other is a high temperature test which inactivates most gram
negative bacteria due to heat stress.  Not many bacteria continue to grow under the stress test. The rest may become
viable, but nonculturable by standard culture methods. As for survival, the EPA document
Control of Pathogens and
Vector Attractions (2003) states bacteria may survive for one year in the soil and six months on plants.

Richard Reding, Ph.D, Chief, EPA Engineering and Analytical Support Branch, February 3, 2009 letter, explains that
fecal coliform grow at elevated temperatures.
"Thus", Reding said, ""inactivation" is by design so as to eliminate
those organisms unable to grow at 44.5 C". ( 112.1 F) It is Dr. Reding's stated contention that only bacteria growing at
elevated temperature have a direct relationship to fecal material from humans as well as cow, pig, sheep, horse, duck,
chicken, turkey, etc.,etc.  Fecal coliform is irrelevant in the real world we live in, all those organisms
(animal, plant, soil
and water) that  are unable to grow at 44.5 C, may contaminate animals, food products, water and infect humans.
They do grow in a low optimum growth temperature medical laboratory test. In spite of that, FDA changed from the  low
temperature food contamination test for coliform to the elevated temperature food contamination test for fecal coliform.
The question is why would EPA and FDA want to inactivate virtually all bacteria in the sludge or food and then claim the
few remaining thermotolerant E. coli are only indicators that there may be some pathogens present? Of course there

  • EPA claims you are completely safe if only 1,000 MPN of fecal colifom per gram of sludge is detectable in
    biosolids used on food & fodder crops and lawns when it leave the treatment facility, even though E. coli will
    double every 20 minutes at normal temperatures.
  • FDA claims your food is safe if it doesn't find fecal  coliform in food products.
  • E. coli has reemerged as an indicator, partly facilitated by the introduction of newer methods that can rapidly
    identify E. coli.
  • FDA states E. coli "can be opportunistic pathogens that cause infections in immunocompromised hosts."
  • Chemicals can suppress immunity and non-pathogenic E. coli can kill  within 24 to 48 hr.
  • Waste & Water industry claims your water is safe if no fecal coliform is found in water.

It would appear the regulators and industry do not: 1) understand the metric system; 2) understand that fecal coliform is
the name of a cheap simple test for thermotolerant bacteria, primarily E. coli; 3) understand that
E. coli is a disease
causing organism unless it has been genetically modified; 4)understand that elevated temperature retards or stops
bacterial growth; 5) understand that coliform is a generic term for members of the family (of gram negative bacteria)
Enterobacteriaceae -- many of which are pathogens; and
6) understand they don't  need a fecal indicator for
sludge biodolids because it is fecal matter.

Fecal coliform
is the name of a test for gram negative mesophilic members of the Enterobacteriaceae (primarily E.
family of facultative anaerobic rod-shaped bacteria that ferments lactose to produce acid and gas at elevated
temperatures within 24 hours. Newer methods that can rapidly identify E. coli within 24 hours made it possible to ignore
Citrobacter, Klebsiella and Enterobacter as well as Salmonella, Shigella,  Yersinia, etc.,  which may also grow at
elevated temperatures. Heat stress of test usually retards or stops bacterial growth.

Coliform is the name of a test for gram negative mesophilic members of the Enterobacteriaceae (primarily E. coli)
family of facultative anaerobic rod-shaped bacteria that ferments lactose to produce acid and gas at normal
temperatures within 48 hours. Newer methods that can rapidly identify E. coli within 24 hours and
suppress Aeromonas
spp made it possible to ignore Citrobacter, Klebsiella and Enterobacter as well as Salmonella, Shigella, Yersinia etc.,
which also grow at normal temperatures. At normal temperatures E. coli normally doubles every 20 minutes.
The Loftus Chart --  Biosolids, Food, Hospital and Water Testing Temperatures
EPA's Engineering and Analytical Support Branch claims fecal coliform growing well above the internal human body
temperature limit has a direct relationship to fecal material. It is also interesting that while EPA will admit
E. coli,
Citrobacter, Klebsiella and Enterobacter are part of the coliform group -- it claims they generally do not cause harm
(citing 1982-83 studies). In this instance, EPA does not, or will not admit,
Salmonella, Shigella,  Yersinia, and others
belong to the same group. Most are pathogens or have pathogenic strains.

Pathogenic Disease Tables EPA and sludge experts do not want you to know about health damage from these
bacterial viruses, and other disease organisms as outlined in medical studies.

                                                   EPA and sludge experts do not want you to know about these disease organisms in
sludge or their relationship to coliform and fecal coliform. Most of all they don't want you to know that 30 years ago
scientist could find Staphylococcus in sludge, yet now that MRSA is pandemic, some sludge scientists claim they can't
find Staphylococcus anymore!!!
    To ascertain the health risks that may be posed by the land application of sewage sludges, a scheme was
    devised to determine the types and numbers of pathogenic and potentially pathogenic bacteria present in
    sludges. A processing treatment was adapted to sludge to give a homogenate which yielded the greatest
    numbers of viable bacteria. Conventional methods were successful in enumerating Klebsiella, Staphylococcus,
    gram-negative enteric bacteria, and commonly used indicator organisms. Modifications of conventional
    methods improved the enumeration of Salmonella, Mycobacterium sp., fluorescent Pseudomonas sp., and
    Clostridium perfringens. However, Shigella methodology yielded only one isolate. Utilizing the proposed
    scheme, the population densities of these organisms were estimated in three domestic wastewater sludges. In
    light of these results, the potential impact of land application of sewage sludges is discussed.

While the authors suggested:
    Pathogens removed through wastewater treatment should not be reintroduced into a population
    via new reservoirs that may be established by irresponsible land management of application sites.

It was their opinion that:
    Acreage set aside for food crops that undergo heat processing, for fiber crops, or for forest products can be
    utilized reasonably for land disposal. However, other agricultural and recreational lands should not be
    utilized as application sites for primary and digested sludge  disposal unless the residual has been
    further treated by composting, irradiation, or pasteurization.

However, composting, irradiation, or pasteurization does not kill all pathogens either:

1988 primary sludge compost study used to promote part 503 was only distributed to 12 regional depository
libraries because the author stated:

  • "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."      
  • The plague causing bacteria Yersinia was consistently found in static pile compost. CDC authorities
    state,  "Outbreaks in people still occur in rural communities or in cities."
  • significant increases in bacterial populations, including salmonellae, occurred during subsequent
    production of commercial soil amendment products.

But, what about pathogenic fungi, yeast and Viable, But Non-culturable pathogens (VBNC)????

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 or higher for three days!

It would appear that publishers and sludge scientists are not aware Salmonella is a part of the coliform group.
Biocycle , June of 1996,  "Pathogen Destruction and Biosolids Composting" "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. 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)

Don't you think this terrible EPA joke has gone on long enough? All disease causing organisms are
opportunistic pathogens. Unless we are immunocompromised hosts, we do not get infections. The Black
Plague and the Spanish Flu only killed immunocompromised hosts just as in the current Salmonella and E.
coli outbreaks. We need sludge biosolids testing at optimum pathogen growth temperature where we get

Time to talk to your Congress person?

Or do like the folks in Pennsylvania
Speak Out  http://www.youtube.com/watch?v=9585nNP1pQY