Table 1 Family Enterobacteriaciae, (Coliform -- fecal coliform infections found in medical studies which may cause death)
EPA  list
Septicemia -
Blood Poison
Urinary tract
(Flesh eating)
Escherichia coli
Hafnia alvei
          Perception Management of Coliform Bacterial Diseases & Biosolids
     Fecal Coliform is the Name of a Test, Not an Indicator of Pathogens

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

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 information.

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
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

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
found "Twenty-five percent of the Houston samples had an average of 22,000 coliform bacteria per gram of sample"  (of cooked
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 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,
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
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,
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 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.

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

(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 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 coliform bacteria is

According toMeckes,  "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 bacteriology"

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 1989, EPA listed 3 of the coliform bucket (E. coli, Salmonella and Shigella) as primary pathogens in sludge and claimed they only caused
gastroenteritis --diarrhea.  This information was removed from the final Part 503 sludge policy because no farmer or health agency would
knowingly allow it where food crops are grown, cattle are grazed, and children play. Diarrhea (gastroenteritis) has not been included as a
part of the following tables of illnesses associated with coliform bacteria that may cause death. This paper does not address
,  enterotoxins or neurotoxins associated with living or dead coliform bacteria that may make you wish for death. Nor is this is  a
complete list of coliform bacteria or illnesses.

Addition Disease/death Tables: 2)
Pathogenic Bacteria; 3) Viruses; 4) Helminths; 5) Protozoa; 6) Fungi; 7) inorganic chemicals;
Synthetic organics; 9) Volatile organics; and 10) 403/503 TOXICS - hazardous waste


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 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 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°F)

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 leaves."

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 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

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 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 meeting
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 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 Program.

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 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)
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 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 were low and thus exposure levels may not have been comparable to those in this study."

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 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