Fecal Coliform (E. coli) Test for coli bacilli
                      Sludge -- Biosolids -- Food -- Water
                              Puts Public Health at Risk

Jim Bynum, VP, &  Gail M. Bynum, Ph.D                                          Revised 6/4/2009                  
Help for Sewage Victims

Neither the fecal coliform test nor any laws (Solid Waste, Hazardous Waste, Clean Water)
protect farmers and the public who are not being told the truth about sludge contaminated with
pathogenic microorganisms.  Sludge is: 1) a solid waste; 2) a hazardous waste because of E.
coli and other pathogens; and 3) a point source pollutant. The current use of the fecal colifom
test itself is designed to inhibit the bacterial growth so as to reduce the number of viable but
culturable E. coli to less than one percent of the total. It eliminates most indicator E. coli in the
sludge sample by making them viable but nonculturable by standard culture methods. This
allows unknown amounts of anitbiotic resistant pathogenic superbugs to be spread on farms,
parks, school grounds and even home lawns. This practice violates any government regulation
for work place safety, especially laboratory safety rules.

June 2006, EPA released the laboratory protocol , Method 1681: Fecal Coliforms in Sewage
Sludge (Biosolids) by Multiple-Tube Fermentation using A-1 medium
. EPA listed  the following
laboratory biosafety level 2 practices which must be followed to protect the workers handling
and spreading sludge:
  • The analyst must observe normal safety procedures required in a microbiology
    laboratory while preparing, using, and disposing of media, cultures, reagents, and
    materials, and while operating sterilization equipment.
  • Field and laboratory staff collecting and analyzing environmental samples are
    under some risk of exposure to pathogenic microorganisms. Staff should apply
    safety procedures used for pathogens to handle all samples.
  • "WARNING: The drying oven should be contained in a hood or be vented.
    Significant laboratory contamination may result from drying a heavily contaminated
  • Samples, reference materials, and equipment known or suspected to have viable
    bacteria or viral contamination must be sterilized prior to disposal.

Method 1681 is a 51 page document full of charts, graphs and mathematical formulas used to
estimate the probable number of heat inhibited E. coli that could be found if the sludge was
actually completely dry.  The test generates no useful information concerning the infectious
nature of sludge, unless you know fecal coliform is E. coli, a pathogen. Moreover, the test
ignores all
other pathogenic microorganisms as well as many inorganic chemicals, synthetic
organic chemicals and volatile organic chemicals which are covered elsewhere. The results of
using the fecal coliform test can be seen in the
increased disease levels and serious illnesses
caused by
bacteria, viruses, helminths, protozoa, and fungus disposed of on agricultural crops.
This is also reflect in the number of
foodborne illnesses which exploded from 2 million in 1986 to
81 million case in 1997. In 1998 CDC estimated there were 360 million cases of acute diarrhea,
most from unknown sources of exposure. CDC's estimate for foodborne illness was dropped to
76 million in 1999 after the
Monterey Regional Water Pollution Control Agency (MRWPCA) and
the Monterey County Water Resources Agency (MCWR partnership completed a $78 million
project to irrigate 12,000 acres of California's best spinach and lettuce crop land in the Salinas
Valley with "reclaimed" sewage water. No new numbers for foodborne illnesses have been
released for the past 10 years. However,  the publicized outbreaks of foodborne illnesses
attributed to contaminated Salinas Valley vegetables have increased.

Many of the foodborne illnesses are caused by coliform bacteria. According to
Comprehensive Veterinary Dictionary, 3 ed. © 2007 ,
coliform is defined as: "pertaining to
fermentative gram-negative
enteric bacilli, [rod-shaped bacterium] sometimes restricted to those
fermenting lactose, i.e.
Escherichia [coli], Klebsiella, Enterobacter and Citrobacter. A wider
range is also used and includes
Pseudomonas aeruginosa, Pasteurella spp., and Aerobacter
aerogenes." The wastewater industry claims these coliform are not pathogens.

The Coliform test is actually restricted to the
Enterobacteriaceae family of bacteria incubated at
35-37°C (95-99°F)  for 24-48 hours, which also includes Salmonella, Shigella, Yersinia and
others. However, this test would reveal too many pathogens. Therefore, the elevated
temperature fecal coliform test for E. coli is used to indicate sludge (biosolids) is safe, while
indicating possible fecal contamination in  food and water.

The Fecal coliform Test  

The safety of sewage sludge and reclaimed water used on farms, parks, school grounds, home
lawns and gardens is based on a 105 year old elevated temperature test to detect
thermotolerant forms of E. coli in food and water, presumed to be of human fecal origin.

The fecal coliform fermentation test requires wastewater treatment plants to incubate the sludge
sample at 44.5° C. (112.1° F) for 24 hours. According to EPA. "These [
test] methods (1681) use
culture-specific media and elevated temperature to isolate and enumerate fecal coliform
organisms." Furthermore, "The predominant fecal coliform is E. coli."

To put that in context, like bacteria your body responds well biologically at an internal
temperature of 98.6°F. However, as the internal body temperature rises you and the bacteria
become heat stressed. As the temperature approaches 105°F the brain and body cells start to
shut down.  Unlike the gram negative bacteria E. coli, before your body temperature reaches the
thermotolerant test temperature of 112.1°F, your are dead. Furthermore, unlike you, when the
temperature drops and it finds moisture, the bacteria will repair its heat damage and move on
with its life.

In his 1904 elevated temperature test for detection of fecal contamination in food and water,
Christiaan Eijkman found that elevated temperatures did not kill coli bacilli (Escherichia coli).
However, he found the elevated temperature did either reduce or eliminate growth in similar
types of coli. He assumed  therefore thermotolerant E. coli was from warm blooded animals only
and all other coli like bacteria (Enterobacteriaceae) were from cold blooded animals.

One hundred and five years later scientists have established that E. coli is the lead pathogen of
the Enterobacteriaceae (
coliform) family of human, animal, soil and water bacteria of which
many are pathogens. Human pathogens grow best at the optimum temperature of 35-37°C (95-
99°F).  At this optimum temperature, with proper nutrients, E. coli doubles every 20 minutes.
Therefore, in 3 hours and 20 minutes, one  (1) E. coli colony forming bacteria doubling every 20
minutes would exceed the Class A requirements of 1,000 E. coli per gram by 24 bacteria. Four
hours and 40 minutes later the Class B requirements of 2 million E. coli per gram would also be
exceeded. At the end of 10 hours, that one bacteria would have multiplied into 1 billion, 073
million, 741 thousand, 824 bacteria. By the end of hour 11, the number would increase to 8
billion, 589 million, 934 thousand, 592 bacteria.  However, in the magical world of sludge we only
have one Colony Forming Unit (CFU). The rest of the bacteria don't count.

According to preamble to part 503, "EPA concluded that the use of fecal coliform is sufficient to
indicate the presence of pathogenic organisms in sewage sludge."  "Fecal coliform was selected
for the final part 503 regulation because an analytical method exists for fecal coliform and
because treatment works conduct fecal coliform analysis routinely." (FR, 58, vol. 32, p. 9348)

In 2007 email,
EPA's Mark Meckes  states that "The fecal coliform group is a subset of the total
coliform and it is also defined by the method used for detection. These are facultative
anaerobic, gram-negative, non-spore-forming, rod-shaped bacteria that ferment lactose
EC medium) with gas and acid formation within 24 hour at 44.5 degrees C."

The key words are
EC medium. EC specifically refers to a culture medium used to detect E.
coli. According to Perry and Hajna's study
Further Evaluation of EC Medium for the Isolation of
Coliform Bacteria and Eschericbia coli, (1944),   EC medium was developed for the isolation of
coliform bacteria at 37°C and of
Escherichia coli at 45.5°C. They say, "EC medium was found
highly specific for Escherichia coli at this temperature."

However, for type II E. coli, the test was only specific for 21.8% of the cultures. In the 1958 study
The Coliform Group II. Reactions in EC Medium at 45° C      Geldreich, et al., said, "There were
5794 cultures of coliform bacteria from untreated surface water supplies of 14 treatment plants
examined. Of the 1358 E. coli included, 83.7 per cent showed positive EC reactions. When the
E. coli strains are subdivided into varieties I and II (see table 1), the percentage of positive
results were 92.7 and 21.8, respectively. The remaining 10
IMViC types yielded 7.8 per cent
positive tests for 4436 cultures." The coliform bacteria are typed by the name of the tests IMViC:
Indole, Methyl red, Voges Proskauer, and Citrate. There are more than two types of E. coli.

E. coli 0157:H7  does not show a positive reaction in the test, yet produces a deadly shiga toxin
gene (STEC ) which first appeared in a Central America Shigella outbreak. In a retroactive
Importation of Shiga Bacillus Dysentery Into California, researchers S. BENSON
WERNER, M.D., RONALD R. ROBERTO, M.D., AND JAMES CHIN, M.D., Berkeley, identified 20
cases of this unique strain of Shigella that occurred during the 1969/70 outbreak.

The first E. coli 0157:H7 case (a Naval Officer) documented with samples at CDC was in
Oakland, California in 1975. The next appearance was when it was determined that E. coli 0157:
H7 shiga toxin contaminated the Jack in the Box hamburgers. The Jack in the Box hamburgers
that sickened several hundred people in 1982, causing the death of four children. The Shigella
like toxin (a known neurotoxin that produces delayed limb paralysis and death) was sequenced
in 1986.  It was noted that Escherichia coli of various serotypes, Salmonella typhimurium, and
Vibrio choterae also produce the toxin. Researchers at Walter Reed Hospital had cloned the
toxin producing gene by 1987.

Early scientists first acknowledged the problem with the fecal coliform test in a 1963 Public
Health Service Report,
ORGANISMS IN SURFACE WATER, "Because no satisfactory method is currently available for
differentiating fecal coliform organisms from human and other animal origin, it is necessary to
consider all fecal coliform organisms as indicative of dangerous contamination." Yet, Knowing
that the test temperature inhibits E. coli growth, in 2002,
FDA's Bacteriological Analytical Manual
Online  shows an increased temperature analysis from 35-37°C (95-99°F) to 45.5°C (113.9°F)
for  food testing  and 44.5°C." (112.1°F) for water, shellfish and shellfish harvest water analyses
This test was re-designated fecal coliform.

According to Ron et al, in there study
Growth Rate of Escherichia coli at Elevated
Temperatures: Reversible Inhibition of Homoserine Trans-Succinylase  (1971), "The preceding
paper [Ron, et al.1970] showed that the growth of Escherichia coli is slowed, without killing, at
40 to 45 C, and that in the several strains tested the cause is a decrease in the activity of
homoserine trans-succinylase. These temperatures are now shown to inhibit the enzyme
directly, in crude extracts and after partial purification. The effect is rapid and is
, unlike the progressive and slowly reversible changes of conventional denaturation."

In 1974 when Gerald Berg, Chief, Biological Methods Branch of the EPA's National
Environmental Research Center in Cincinnati, Ohio warned of the inadequacy of the fecal
coliform test, even though he implied pathogenic strains of E. coli were not part of fecal coliform
. He stated:
    For some time we have been aware that fecal coliforms are not always reliable
    indicators for viruses and that neither fecal coliforms nor other bacteria are
    inviolate indicators of fecal pollution. To be sure, fecal coliforms indicate a sanitary
    hazard, but certain other bacteria may seem to be fecal coliforms in the standard
    membrane filter test. Moreover, fecal coliform may multiply in waters where
    pathogenic bacteria and certainly viruses cannot. And fecal coliforms may be
    destroyed in waters polluted with certain industrial wastes -- wastes that do not
    seem to affect fecal streptococci and may not affect viruses either. Clearly, it is a
    matter of some importance to develop a bacterial indicator system that can
    definitively differentiate fecal organisms from free-living forms. (p. xii)

According to
Merck's Fact Sheet, "Lactose-positive bacteria produce yellow-orange colonies
and under the membrane yellow halos. The count of these typical colonies is considered to be
presumptive coliform bacteria count." "Colonies that are oxidase negative are considered to be
coliform bacteria. Coliform bacteria that form indole [gas] from tryptophan at 44 ± 0,5 °C within
21 ± 3 hours are considered to be E.coli."

E. coli does not die quickly or easily. It may not die at all but be in a dormant state as in
stationary phase death and heat-shock response. According to
A. Eisenstark, et al, Cancer
Research Center, Columbia, MO, (1992) "When Escherichia coli cells reach stationary phase of
growth, specific gene products are synthesized that protect cells while dormant. "Aged" cells
may remain viable in cultures for years. For example, agar cultures stored for 38 years still had
more than10(5) [100,000] viable cells/ml. However, when specific mutants were cultured, the
population of these mutants dropped sharply after 4-10 days. This defect is termed "Stationary-
Phase-Death". Each mutant strain was hypersensitive to near-ultraviolet radiation and other
oxidative agents. Bovine catalase rescued many of the mutants from death in dormancy,
suggesting that specific gene products protect "aged" cells against oxidative damage."

According to
Fritz Schöffl, et al, Universität Tübingen, (1999), "The heat-shock response is a
conserved reaction of cells and organisms to elevated temperatures (heat shock or heat
stress). Whereas severe heat stress leads to cellular damage and cell death, sublethal doses of
heat stress induce a cellular response, the heat-shock response, which (a) protects cells and
organisms from severe damage, (b) allows resumption of normal cellular and physiological
activities, and (c) leads to a higher level of thermotolerance."

In the paper,
Viable but non-culturable bacteria: their impact on public health, (2005)
Yogita N. Sardessai,Goa College of  Pharmacy, states the problem:
    Viable but nonculturable  "(VBNC) bacteria are a major concern in public health risk
    assessments because many pathogenic bacteria like Vibrio cholerae, Mycobacterium
    tuberculosis, Campylobacter jejuni, Helicobacter pylori, Vibrio vulnificus and Escherichia
    coli have been reported to enter a VBNC state from which they are able to return to the
    infectious state after passaging in animal hosts. Reports indicate that many potentially
    harmful bacteria survive treatment and persist in processed food, pasteurized milk,
    potable water and in the environment."

    "The implications of bacteria to lie in a dormant undetected state are far reaching. For
    instance, antibiotic resistant chronic otitis medium was earlier considered a sterile
    inflammatory process. But it is now known that there are antibiotic-resistant bacteria in
    biofilms which are in VBNC state, causing chronic infection10. The sudden recurrence of
    tuberculosis years after a person was presumed cured has also been attributed to
    resuscitation of VBNC Mycobacterium cells7."

James D. Oliver, Department of Biology, University of North Carolina at Charlotte, 2005, said, "It
had long been assumed that a bacterial cell was dead when it was no longer able to grow on
routine culture media." However,  "Since the original 1982 paper from the laboratory of Rita
Colwell (Xu et al., 1982), over 400 papers have appeared which describe various aspects of the
phenomenon most commonly referred to as the " but nonculturable (VBNC) state" A great many
pathogens, as well as nonpathogens, are now known to enter this dormancy state, and its
significance in medicine, bioremediation, the use of bacteria as fecal indicators, and indeed in
most microbiological studies where culturability is employed as the (often sole) indicator of
viability, is becoming increasingly evident." Moreover,  "a number of studies have found that
processes which are normally assumed to be bactericidal for bacteria may instead result in cells
which reside in the VBNC state. These include such treatments as pasteurization of milk (e.g.
Gunasekera et al., 2002) and chlorination of wastewater (Oliver et al., 2005)." Furthermore,  
"The number of species described to enter the VBNC state constantly increases, with
approximately 60 now reported to demonstrate this physiological response. Included are a large
number of human pathogens, including
Campylobacter spp., E. coli (including EHEC strains),
Francisella tularensis
, Helicobacter pylori, Legionella pneumophila, Listeria monocytogenes,
Mycobacterium tuberculosis, Pseudomonas aeruginosa, several Salmonella and Shigella spp.
Vibrio cholerae, V. Parahaemolyticus, and V. Vulnificus."

Even EPA documents confirm that while heat and chemicals will cause the bacteria to be
inactivated, it is a temporary condition.  EPA states in  
(Part 403.5(b)(5)) that "Heat above 40 °C
(104 °F) and disinfectants
will slow or eliminate biological activity causing some bacteria to
become viable, but nonculturable by standard culture methods" In effect, the test itself slows the
growth of E. coli and eliminates the growth of the other Enterobacterriaceae family causing them
to become viable but nondetectable.

At the same time the fecal coliform test excludes the following pathogenic families: 1)
Gram-Positive Cocci; 2) Aerobic Gram-Negative Cocci; 3) Aerobic Gram-Positive Bacilli; 4)  
Aerobic Gram-Negative Bacilli: Nonenterobacteriaceae—Fermentative; 5) Aerobic Gram-
Negative Bacilli: Nonenterobacteriaceae—Nonfermentative; 6) Aerobic Gram-Negative
Fastidious Coccobacilli; 7) Mycoplasma (Pleuropneumonia-Like Organisms [PPLO]); and 8)
Treponemataceae (Spiral Organisms).  

These families of bacteria contain the most deadly community acquired superbugs.   Among
these are the Invasive
group A streptococcal, Staphylococcus,  MRSA,  Clostridium, most
Necrotizing (flesh eating) bacteria,  and E. coli 0157 which have become epidemic. It also
ignores the deadly community acquired viruses such as swine flu,
Adenoviruses,  arenaviruses,
Herpes viruses
, paramyxoviruses, papovaviruses such as Polyoma virus and Papillomasvirus,
such as enteroviruses, Poliovirus, Coxsackievirus, Echovirus,  and hepatitis A

In a February 2009, e-mail EPA's Richard Reding, Chief,  Engineering and Analytical Support
Branch, pointed out that the heat inactivation of most E. coli and reduction or eliminating other
similar bacteria from the test was by design when he wrote that fecal coliform "are distinguished
from the coliform group by their ability to grow at the elevated temperature of 44.5°C. Thus,
"inactivation" is by design so as to eliminate those bacteria that  are unable to grow at 44.5°C
[112.1° F]."

According to a
July 2007 study, the fecal coliform test would specifically reveal, with the
exception of 0157,  some heat inhibited thermotolerant E. coli strains. Strains growing in drinking
water systems at elevated temperature were, 1) 04 Uropathogenic E. coli,
UPEC); 2) 025
Enterotoxigenic E. coli,
ETEC); 3) 086 (Enteropathogenic E. coli, EPEC); 4) 0103 (Shiga-toxin
producing E. coli,
STEC); 5) 0157 Shiga-toxin producing E. coli, STEC); 6) 08 Enterotoxigenic E.
ETEC); and  7) 0113 Shiga-toxin producing E. coli, STEC).  

CDC  documents indicate the infective dose for E. coli is estimated to be  only 10-100 non-heat
stressed organisms. E. coli doubles every 20 minutes, which means that if you are infected with
only one bacteria,  in 2 hours you are well past the infection stage.

Other non-0157 serotypes of E coli –eg O29, O39, O145  produce shiga-like toxins, causing
bloody inflammatory diarrhea, evoking Hemolytic uremic syndrome (HUS). A
ccording to the
Oklahoma Department of Health,  enterohemorrhagic Campylobacter, Shigella, Salmonella, and
Yersinia may cause Hemolytic uremic syndrome (HUS) , a disease that destroys red blood cells
and causes kidney failure,  primarily affecting children. Furthermore, according to the
Department of Health, "Not all cases of HUS are caused by shiga toxin; while uncommon, a
variety of viral and bacterial infections, as well as some cancers, can cause HUS"  Hospital cost
for a HUS victim is about $100,000.00. Between 8% of HUS victims treated without antibiotics
and 50% treated with antibiotics die.

According to
Meridian Bioscience, STEC infections are very serious because: 1) Antibiotics
increase Shiga toxin release and production and should be avoided: 2) HUS [Hemolytic uremic
syndrome] develops in 56% of STEC patients treated with antibiotics; 3) HUS develops in only
8% of STEC patients not receiving antibiotics; 4) 38%-61% of patients with STEC infection will
develop Hemorrhagic Colitis; 5)  5%-10% of patients with STEC infection will develop HUS; 6)
Approximately 10% of those with HUS will die or have permanent renal failure; 7)  30%-50% of
all STEC infections are caused by E. coli
non-O157; 8) 50% of HUS cases are caused by non-
strains of E. coli; 9) SMAC culture misses as much as half of all O157:H7 and all non-
O157 strains of E. coli; and 10) Hospital cost of care for one HUS is approximately $100.000.

The reality is that the only thing the fecal coliform test proves is that there are an unknown
quantity of viable pathogens in sludge. While there may be some non-pathogenic strains, the
International Escherichia and Klebsiella Centre (WHO) has a collection of approximately 60,000
E. coli strains, most of which are clinical isolates. No one has any idea how many or what type of
unknown and viable but nonculturable pathogens are in sludge and reclaimed water when the
test sample is drawn, much less after the test is completed due to the elevated temperature of
the test.

The number of these  thermotolerant E. coli strains that survive the heat and  react to EC
medium (two million CFU per gram (0.035273 oz) Most Probable Number (MPN) dry weight -
Class B and 1,000 CFU per gram - Class A) allowed in sludge are mathematical assumptions
based on charts and graphs of heat inhibited growth of E. coli bacteria in sludge and the density
of the sludge being converted from liquid to total solids.  The CFU refers to the number of
bacterial colonies technicians are able to count after 24 hours. The Most Probable Number used
for classifying sludge is the assumed number of original bacteria spiked in the test 24 hours
earlier. Meaning that each colony is counted as one bacteria at the start of the test. That does
not included bacteria tightly bound in biofilms.  For Class B sludge that is 56,000,000 E. coli
colonies of bacteria per ounce of sludge or 9,072,000,000 E. coli colonies of  bacteria per
pound of sludge. After undergoing further treatment to reduce pathogens with chemical or heat
treatment for Class A sludge that is  28,350 heat inhibited E. coli Colonies of bacteria per ounce
of sludge or 453,600 heat inhibited E. coli colonies of  bacteria per pound of sludge biosolids.  
Contrast that with the two to 10 most probable number of E. coli Colonies per gram (0.035273
oz) allowed in swimming water.  There is no provision to protect water from receiving bacterial
contaminated runoff from sludge sites  since they are considered by the enforcers of the Clean
Water Act to be unregulated non-point sources of pollution.

Using this outdated test proponents of sludge use claim it proves sewage sludge is safe for use
as a fertilizer on food crops, school grounds and your lawn
if only a few bacteria are found. The
problem is that the elevated temperature test itself inhibits or stops the growth of bacteria in the
sample, while the pathogens in the original material continue to thrive at normal temperatures.

This test does not offer any protection  from contamination of our air, food supply, drinking
water, or health as part 503 only discusses pathogen reduction, not elimination. This is
accomplished by the test itself as we discovered when our farm was contaminated by sludge
runoff.  This was mentioned in the article
Sludge Magic at EPA). Lewis checked with the
laboratory to confirm  the fecal coliform levels were low but Salmonella and E. coli levels were
high. While several tests were done for fecal coliform, the two tests specifically for E. coli and
Salmonella are the most important. However, at the time we did not realize fecal coliform is E.
coli whose growth is inhibited by the elevated test temperature.

Bacteria do not die just because sludge has been treated. In the study
Occurrence of
Pathogens in Distribution and Marketing Municipal Sludges (1988) William A. Yanko,  County
Sanitation Districts of Los Angeles County,  tested  seven municipal sewage sludge compost
products. They were sampled weekly for one year. He found "significant increases in bacterial
populations, including salmonellae, occurred during subsequent production of commercial soil
amendment products."

Treatment causes some of the pathogenic disease organisms to be absorbed or enclosed in
fecal particles during the  treatment process. These are biofilms holding the particles together.
For this reason, In the study
"Survival of pathogenic micro-organisms and parasite in extreta,
manure and sewage sludge" (1991) D. Strauch, Institute of Animal Medicine and Hygiene,
University of Hohenhiem, warned,  "the agricultural utilization of hygienically dubious sewage
sludge poses a risk for the whole national economy."

After reviewing the sludge rule and laboratory reports from our farm, EPA's own David Lewis
warned about the danger to public health from bacterial survival on farms in the article
Magic at the EPA (1999). He said,  "the Sludge Rule on land application of municipal wastes (40
CFR Part 503) promulgated in 1993 may be the most scientifically unsound action ever taken by
the agency. Rather than being protective, the rule actually threatens public health and the

Lewis et al, documented the danger to public health from microorganisms in the study,
Interactions of pathogens and irritant chemicals in land-applied sewage sludges (biosolids)
(2002).  David L Lewis, David K Gattie , Marc E Novak , Susan Sanchez  and Charles
Pumphrey.  They found, "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)."

A 2007 epidemiologic self reporting survey of neighbors near an Ohio biosolids (sludge) site by
researchers from the University of Toledo revealed excessive health problems. The
Survey of Residents Living Near Farm Fields Permitted to Receive Biosolids (2007),  Sadik
Khuder, PhD; Sheryl A. Milz, PhD; Michael Bisesi, PhD; Robert Vincent, PhD; Wendy McNulty,
MS; Kevin Czajkowski, PhD, found that the, "Results revealed that some reported health-related
symptoms were statistically significantly elevated among the exposed residents, including
excessive secretion of tears, abdominal bloating, jaundice, skin ulcer, dehydration, weight loss,
and general weakness. The frequency of reported occurrence of bronchitis, upper respiratory
infection, and giardiasis were also statistically significantly elevated. The findings suggest an
increased risk for certain respiratory, gastrointestinal, and other diseases among residents
living near farm fields on which the use of biosolids was permitted." The permitting is all based
on a fecal coliform test going back to 1904


The fecal coliform test that is used as an indicator for fecal contamination of food and water
does not protect the farmers and the general public from deadly bacteria, viruses, worms,  
protozoa  or fungus found in sludge, a fecal material. Fecal coliform refers to one member of the
coliform (Enterobacteriaceae) family -- thermotolerant types of E. coli, but does not include
E. coli 0157:H7 . This test offers no protection for public health based on the following facts: 1)
most pathogens  grow well at normal temperatures: 2) thermotolerant fecal coliform includes
many pathogenic strains of E. coli and similar bacteria while excluding all other viable but
nonculturable aerobic and  facultative bacteria that thrive at normal temperatures; 3) E. coli is
the primary coliform resistant to heat inactivation and the test doesn't indicate heat resistant
toxins; 4)  biofilms tightly bind pathogens together in sludge particles causing them to be
invisable; 5) heat, chemicals or drugs stresses may damage some E. coli DNA causing it to  
become dormant (be nonculturable-nondetectablle) by standard cultural methods -- only to be
revived by its SOS Response genes; 6) dormant, but viable E. coli cells have survived in
storage for 38 years; 7) the test does not indicate viruses and parasites; and 8) bacteria and
viruses exchanges genes during the sewage treatment process creating more powerful
antibiotic resistant strains of pathogens.

Public health is compromised, farms and associated business are damaged or destroyed,
surface and ground water are contaminated, animals and people are sick, dead and/or dying
based on a  105 year old fecal coliform test that proves pathogen contaminated sewage sludge
is being disposed of as a fertilizer or soil amendment. Based on twenty years of research, there
is currently no scientific or management method which would safely allow the use of sludge or
reclaimed water on legitimate farming operations for any reason or for any other public purpose.
Test 1
Laboratory report counts colonies
per 100 grams of soil at end of test
Fecal coliform is heat inhibited E. coli
Most Probable Number (MPN) of
per gram of soil placed on
culture at beginning of test.
Fecal Coliform
3,000 colonies per 100 grams of soil
30 MPN per gram of soil
E. coli
>800,000 colonies per 100 grams of soil
>8,000 MPN per gram of soil
Test 2
Fecal coliform
9,000  colonies per 100 grams of soil
90 MPN per gram of soil
>800,000 colonies per 100 grams of soil
>8,000 per gram of soil
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