Malfeasance Or Culpable Ignorance?

Jim Bynum,vp                              
Help for Sewage Victims

  • Coliform: Enterobacteriaceae
  • Culpable ignorance:  lack of knowledge or understanding that results from the omission of ordinary care to
    acquire such knowledge or understanding.
  • Dogma: a point of view or tenet put forth as authoritative without adequate grounds such as that coliform and
    fecal coliform are only harmless indicators of potential fecal pollution in food or water.
  • Fecal coliform: thermotolerant E. coli.
  • Malfeasance: wrongdoing or misconduct especially by a public official.


Federal and state politicians enact laws to preserve unborn embryo, yet have no interest in protecting that embryo in
the fetus stage from exposure to toxic chemical and pathogenic pollutants the mother is exposed to through food and
water. Once the  fetus has emerged into the real world it is no longer a concern of the politicians, that is, until it
become a part of the public health crisis sweeping across the nation caused by the same politicians. Then they
become a drain on the national economy. Some members of this highly religious Congress have determined that these
children and their mothers have no right to medical treatment unless they can afford to pay for it out of their own

Former Senator (now Governor) Brownback (KS) and Senator Bond (MO), led the charge against protecting children
and women with a 2006 proposed Bill that Confined Animal Feeding Operations (CAFOs) pathogen contaminated
manure shall not be considered to be a hazardous substance [
CERCLA], pollutant [CWA] [503], or contaminant [DWA].
Senator Blunt (MO) picked up their torch and reintroduced the Bill in 2011.

The dumbing down of a Congressional mandated toxic pollutant to a simple pollutant by EPA is a clear indication it is
protecting the polluters and has no interest in enforcing the law or "
continuing its commitment to core environmental
and health protections -- safeguarding Americans from pollution in the air they breathe, the water they drink and the
land where they build their communities
." (Statement to Congress by EPA Administrator Lisa P. Jackson, February 27,
2012, FY 2013 Budget)

It is not that laws are not enacted to offer some protection, they just have too many loopholes on toxics (Clean Water
Act (CWA)) and hazardous waste (Solid Waste Act (RCRA)), when incorporated into Agency Policies to be effective.
Lets be clear, this is just another corporation, run mostly by hidden people with an agenda, which may not be in our
best interest. Think Wizard of Oz, if you are old enough to remember the movie.

In some cases such as the CWA and its bastardized companion policy for the disposal of sludge on agricultural land,
Part 503, the wording and terms are  changed to confused the public as well as attorneys. As an example, the CWA's
definition of  a
pollutant includes, solid waste, sewage, sewage sludge, chemical wastes, biological materials,
radioactive materials, agricultural waste, etc., Whereas, the Part 503.9(t) Sewage Sludge Use and Disposal policy
ignores the CWA and downgrades CWA
Toxic Pollutants to a Pollutant which it defines as organic substances
synthetic], inorganic substances as well as a combination of organic and inorganic substances and pathogenic

Both the CWA and the bastardized sludge policy use the scientific generic term “organisms” to include humans.
Pathogenic organisms are down graded to
fecal coliform indicators. The CWA is further down graded by substituting
the word
Could for Will in the description of the effects these substance and pathogens have on an unborn child and
its mother: “After discharge and upon exposure by ingestion, inhalation, or assimilation into an organism [person]
either directly from the environment or indirectly by ingestion through the food chain
503.9(t)) on the basis of information available to the Administrator of EPA cause death, disease, behavioral
abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunction in reproduction), or physical
deformations in such [individual] organisms or their offspring.”

Nowhere in the bastardized Part 503 policy does its claim to protect public health and the environment, nor does it
claim to have any relationship to Section 405 of the CWA or any other law. In fact, it states to comply with Section 405,
sludge must be disposed of under the CWA's solid waste regulation Part 258. Yet, it removed sewage sludge from
under the
Solid Waste Law (RCRA) which states these hazardous substances in solid waste, including infectious
"may cause, or significantly contribute to an increase in mortality or an increase in serious
irreversible, or incapacitating reversible, illness; or (B) pose a substantial present or potential hazard to human health
or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed."

These irresponsible actions by Congress, federal agencies and the states, have create a public health crisis with
multiple ongoing
pandemics putting extreme stress on families as well as our health care system.


After funding a thirty year old public relations program to dumb down and educate the public to accept the spreading
pathogenic disease causing organisms on our food and in our water based on EPA, FDA and USDA dogma that
coliforms are harmless, Certain members of Congress have attempted for the past seven years to remove the manure
generated by CAFO's from federal CERCLA (Superfund) regulations to make certain that "manure" is not considered a
hazardous substance under EPA regulations. Not because of pathogens, but because in 2001, "A federal district court
ruled that phosphate in manure is a hazardous substance under the Superfund law or SARA, i.e., the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA)."

There is more to this story. EPA has a habit of strategically losing federal court cases when it wants to protect big
business. The aim of the court case is not alway readily apparent. In this case cattle have been considered as
reservoirs of infectious shiga toxin-producing coliforms which would make manure a hazardous waste under the Solid
Waste Act.  As an example, according to the Kansas Department of Health there are mandatory reporting
requirements for over 100 serotypes of dangerous infectious coliforms. The investigation guide states, "More than 100
serotypes of E. coli produce Shiga or Shiga-like toxins. -- Escherichia coli enteric infection from E. coli 0157:H7 and
other shiga toxin-producing E. coli,also known as STEC, shall be designated as infectious or contagious in their
nature, and cases or
suspect cases shall be reported within seven days." http://www.kdheks.

Accurate information is hard to come by, but approximately five million dry tons of sludge is disposed of on agricultural
land mixed in sewage effluent at between 1/2 and 25 percent solids. That translates into about 100 million tons of
chemical and pathogen contaminated sludge mixed with water, which is essentially concentrated sewage used for
irrigation. Manure from CAFOs is estimated to be about 500 Million tons with 250 million tons disposed on agriculture.
Agricultural stormwater carrying the hazardous substances and pathogens in sludge and manure into the nearest
water source are exempt from federal law. Some of these are then recycled back through our drinking water systems.

On Jul. 19, 2006,
Senator Brownback (KS) and Senator Bond (MO), among others, introduced S. 3681, "A bill to
amend the Comprehensive Environmental Response Compensation and Liability Act of 1980 to provide that manure
shall not be considered to be a hazardous substance, pollutant, or contaminant; to the Committee on Environment and
Public Works (Congressional Record: July 18, 2006 [Senate], Page S7752). On 10/18/2011, the Bill was again
introduced as S.1729 by
Senator Blunt (MO) with six co-sponsors. They were successful in 2009 with an exemption  for
air pollution effective January 20, 2009: “
CERCLA/EPCRA Administrative Reporting Exemption for Air Releases of
Hazardous Substances from Animal Waste at Farms,” is an exemption from the existing notification requirements in the
1984 final rule on the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) notification

Couple that information with recently finding four senior EPA employees involved in the approval of a Master Thesis in
Epidemiology from a major university claiming exposure to high levels of  fecal coliform offers immunity from mesophilic
E. coli 0157 infections is just too far over the top to let it pass. This is a major case of dumbing down education. It could
be a case of educational malfeasance by EPA employee mentors and a Committee member committed against the
student who worked hard and paid good money to earn that graduate university degree. It is evident EPA employees
should have known that fecal coliform is thermotolerant E. coli, while E. coli 0157 is not, whereas the student and his
instructors did not.

In the past 30 years, our government's actions in regard to education, research and testing of food, water, sewage,
and sewage products has resulted in a decline of scientific integrity and outright fraud. How did we get to the point that
it is illegal to lie to government agents, but it is not a problem for them to lie to us and put our children at risk?

It is definitely time to take a close look at the data behind the dogma, especially when you consider the average
economically cost for an acute infection through food and water can run between seven thousand dollars for those that
appear to have a complete recovery to six million dollars for those that lead to death from bacteria such as E. coli
0157, MRSA, etc..  Just to be clear, if I didn't personally have the test to back up the difference between
thermotolerant  E. coli (fecal coliform) and E. coli on a farm I could be sued under food slander laws in at least 13
states.  After two decades of research, that is not going to happen because the data exposes the dogma behind
agency policies.

Since the regulations only suggest the possibility of serious health effects which would be difficult to prove, the
regulations promote the contaminate waste to be spread on agricultural land.  The organic and inorganic pollutants
are sucked up by leafy green plants with relatively long term health risks. The more immediate and urgent danger this
paper will focus on are pathogenic mesophilic
Enterobacteriaceae (total coliform) and thermotolerant/thermophilic E.
coli (fecal coliform). The terms thermotolerant, thermophilic, fecal coliform are used interchangeable for those gram
negative bacteria, especially E. coli, that ferment some gas or acid at 7 degree C (13.5 degree F) above their optimum
growth rate, which is the same as the normal human body temperature.

To illustrate the point, pathogen contaminated  sewage sludge is given to farmers and schools as a safe fertilizer and
forced on neighboring agricultural communities by state legislators based on a limiting the amount of thermotolerant
bacteria. Not only that, but "reclaimed/recycled" sewage effluent is sold as safe irrigation water for food crops eaten
raw such as lettuce and spinach. The claim of safety is based on allowing a certain amount of "harmless" coliform
bacteria such as
E. coli, Klebsiella, Enterobacter, Citrobacter, Salmonella, Shigella, etc. to slip through the treatment
systems under federal or state permits. This transfers liability for
hazardous waste from municipalities to farmers, their
neighbors, brokers, distributors, retailers and consumers.

The dogma within some educational institutions is that federal and state regulations protect us from infectious
pathogens through food and water by controlling the amount of fecal coliforms released into the environment in
manure and sewage "products". The data shows that federal and state regulations actually encourage the spreading
of hazardous infectious pathogenic coliforms through "treated" sewage effluent and sludge as well as recycled sewage
effluent by being dogmatic in the claims that: (1) they are running out of landfill space; 2) coliforms are either
environmental, or from coldblooded animals, and not pathogenic to humans; (3) thermophilic/thermotolerant strains of
"fecal" coliform only indicate possible fecal pollution; (4) only thermophilic strains of generic E. coli (fecal coliform) are
from humans and other warmblooded animals; and (5) other thermophilic strains of coliform are environmental with no
sanitary significance. That is educational malfeasance as well as a  violation of a public trust.

No one knows for sure the exact number of illnesses and deaths caused by antibiotic resistant coliform and non-
coliform waterborne and foodborne disease causing organisms released to the environment from CAFOs, sewage
treatment plants in sewage effluent, sludge and reclaimed effluent water dumped in surface water and on agricultural
land where it contaminates animals, crops, surface and groundwater. In a 1986 landfill risk assessment for
EPA, Dr.
Charles Gerba (UA) estimated there were two million foodborne illnesses annually. In 1998, the Honorable
John D.
Dingell testified, "According to a recent General Accounting Office (GAO) report as many as 33 million Americans each
year become ill from the foods they eat. We also know that many cases of food-borne illness are not reported. GAO,
therefore, estimates the total number of food-borne illnesses to exceed 81 million each year. Among these cases,
more than 9,100 result in death." Currently, with the explosion of foodborne illnesses,  
CDC sets the number of
foodborne illnesses at 48 million, midway between the range of official estimates (28.7 to 71.1 million) and with deaths
at 3,037, midway between the range of estimates (1,492 to 4,983).

Most government leaders and scientists will plead ignorance when ask to identify the makeup of the coliform group
(E. coli-like-forms) in food and water to prevent the public from panicking. Many coliforms are antibiotic resistant
Superbugs on the list of
potential bioterrorism agents such as: Edwardsiella tarda; Escherichia coli, all
enteropathogenic serotypes;
Klebsiella - all species and all serotypes; Proteus – all species; Salmonella - all species
and all serotypes;
Shigella - all species and all serotypes; and Yersinia (Pasteurella) pestis, Y. Enterocolitica. Currently
federal and state rules allow drinking water treatment plants to fail 5% of the required monthly test for these coliform
pathogens even though one failure contaminates the system and allows biofilms to grow. When biofilms mature they
spew out bacteria recontaminating the system with the potential for disease and death.  Just as important, these
pathogens are allowed to be spread on agricultural land as sludge fertilizer and reclaimed water for irrigation where
they are permitted to contaminate animals, food crops and water with growing biofilms. They are also allowed in sludge
and reclaimed water used on lawns and public parks where children play.

Fraud raises its ugly head when the next step after identifying the presence of coliform bacteria in water is to test for
thermophilic fecal coliforms as an indicator of fecal pollution.  The industry gatekeepers will tell you with a straight face
that the scientific consensus is that even though some strains of
Klebsiella are thermophilic antibiotic resistant
superbugs, it is an environmental bacteria rather than an indicator of fecal pollution.  Therefore, it has no sanitary

Due to the fact that there is no economical sewage treatment process to keep these antibiotic resistant bacteria out of
our surface water supply, the government has promoted the recycling of sewage sludge as a fertilizer to unsuspecting
farmers and sewage effluent for irrigation. To do this, government agencies had to dumb down education and science
by creating the dogma to match the national policy.

Dumbing Down Science for Agriculture, Food, Water and Sewage

Jim Hightower, two term Texas Agriculture Commissioner, appears to best explain the evil that has been creeping into
our government, agricultural and educational systems. According to Hightower, "What's happened is that, from Wall
Street to Washington, we now have too many 5-watt bulbs sitting in 100-watt sockets. As a result of our leaders'
dimness, America's uniting and constructive ethic of "We're all in this together" and "Together we can" is being
supplanted by a shriveled, dispiriting ethic that exalts plutocratic selfishness and scorns the public interest as intrusive,
wasteful, ideologically impure and morally ruinous."

No one, especially municipalities, want to find any pathogenic bacteria in drinking water, but it is virtually impossible to
prevent some from getting through the treatment system. Therefore, a cheap test for the  "colon group" of gram
negative bacteria that reacted to four test media within 24-48 hours: (a) indole; (b) methyl red; (c) Voges-Proskauer;
and (d) citrate, at normal body temperature was chosen to enumerate "harmless" Enterobacteriaceae (coliform). The
problem is, they are not harmless.

The thermophilic strains of (fecal) E. coli that show some growth well above the optimum growth temperature most
disease causing organisms are claimed to be indicators for other pathogenic mesophilic organism species which are
more costly, if it were possible, to isolated such as: Aerobic Gram-Positive Cocci; Aerobic Gram-Negative cocci;
Aerobic Gram-Positive Bacilli; Aerobic Gram-Negative Bacilli: Nonenterobacteriaceae— Fermentative; Aerobic Gram-
Negative Bacilli: Nonenterobacteriaceae—Nonfermentative; Aerobic Gram-Negative Fastidious Coccobacilli;
Mycoplasma (Pleuropneumonia-Like Organisms [PPLO]); and Treponemataceae (Spiral Organisms). It is assumed that
somehow, someway, they will also indicate the presence of viruses, and parasites such as helminths and protozoa.

In 1914 the Public Health Service actually adopted the term coliform for the "colon group", a small group of coli-like-
forms of bacteria producing gas and/or acid from lactose within 48 hours.  However, no one wanted to acknowledge
that E. coli was the primary member of the group and a known killer of women and children (
child bed fever) in
hospitals. Harry Jordan, the first hired Executive Director of the American Water Works Association alleviated  the
problem by refusing to publish the names, E. coli or colon group, in its Journal after 1937. In 1939,
Department of Bacteriology, Hygiene and Preventive Medicine, School of Medicine, The George Washington University
at Washington, D. C., reported that, "In 1937 H. E. Jordan advised that as Editor of the Journal of the American Water
Works Association his policy would be to substitute "coliform" bacteria for "
B. coli" or "colon group" in papers submitted
to him (70)." Furthermore, Parr said, "The oldest members of the coliform group of bacteria, as the reviewer conceives
it, are
Klebsiella pneumoniae, or Friedlinder's bacillus, described in 1882, and K. rhinoscleromatis, which v. Fritsch
recorded the same year. Next come
Escherichia coli and Aerobacter aerogenes, both of which were ushered into the
bacteriological world in 1885 by Escherich. Somewhat younger is
A. cloacae, described in 1890 by Jordan. Proteus
morgani, the problem child of the group, dates from 1908 and the juveniles are E. freundii, recorded in Braak's Delft
thesis of 1928, and
K. paralytica, the etiological agent of "moose disease," described in 1932 by Cahn, Wallace, and

In 1939, A. A. Hajna and C. A. Perry, Maryland State Department of Health, pointed out the problem with coliform
testing in their study, "
COLIFORM BACTERIA". They said, "The only method which has so far been found practical for the isolation of
Escherichia coli from materials harboring other coliform organisms is incubation at a temperature high enough to
suppress the growth of such interfering coliform types. At a temperature of 45° to 46°C., coliform types other than
Escherichia coli usually fail to grow and produce gas from a suitable carbohydrate."

Unfortunately, there are a few other pathogenic enteric coliforms besides Escherichia coli such as the superbug
Klebsiella as well as Citrobacter and Enterobacter which have strains that grow at the same elevated temperature.  
The implication is that these bacteria when found in soils and vegetation don't cause disease in humans. A. P. Dufour
set the stage for dumbing down science in his 1977 work, "
Escherichia coli: The Fecal Coliform" within the book,
Bacterial Indicators /  Health Hazards  Associated with Water" . Dufour said, "Over 90 percent of bacteria in raw
sewage is E. coli.  However, in the treatment plant, E. coli only makes up about a third to a fourth of the bacteria. The
other 3/4 is 25% Klebsiella and 50% Enterobacter-Citrobacter. --- some of which are seldom associated with fecal
contamination -- E.coli is the only coliform that is an undoubted inhabitant of the gastrointestinal tract. -- Klebsiella-
Citrbacter- Enterobacter genera can be easily found in soils and vegetation."

It seems Dufour ignored all other Enterobacteriaceae as well as all non-Enterobacteriaceae and forgot to mention
these particular bacteria cause well over one-half of the urinary tract infections suffered by women. Human infections
were noted in the 1979 study, "
al., said, "Pure cultures of E. coli, Klebsiella and Enterobacter, obtained from hospital patients and from natural waters
were tested for their growth patterns by spread plate and membrane filtration procedures at the following
temperatures; 35°, 41.5°, 43°, 44.5°, and 35°C for 4 h followed by 18 h at 44.5°C. Results indicated that 44.5°C
[112.1°F] incubation produces the lowest population estimate and that the application of the membrane filtration
technique also reduced the potential population. -- Data from these studies indicate that, depending on the age of the
population being measured, the temperature of the water sample, and the temperature-media-procedure combination
used, fecal coliform and E. coli population estimate techniques measure from 5% to 100% of the potential population"

To put this study in perspective for farmers, thermotolerant Fecal coliform has little to do with the amount of mesophilic
E. coli and Salmonella surviving in agricultural soil. As a
personal example, in 1998, I was fortunate enough to take soil
samples on each end of a half section farm down grade of a municipal sludge farm site about a year after the last  
application. Knowing that fecal coliform was the standard to gauge the safety of sludge, each sample was tested for
fecal coliform. As an after thought, I also ask the samples be tested for E. coli and Salmonella. The results were

    Sample 1: Fecal coliform    -- 90 colonies per gram
                Salmonella         --  >8,000 colonies per gram

    Sample 2: Fecal coliform   --  30 colonies per gram
                E. coli                 --  >8,000 colonies per gram

EPA and Missouri regulators suggested ignoring the numbers other than fecal colifrom even though pathogen
contaminated wheat and soy beans were going into the human food chain. Their reasoning was that EPA and FDA
regulations are based on fecal coliform numbers alone and EPA had no rules, or data,  concerning the safe level of
bacteria in soil, not even a risk assessment.   No ethical farmer could, or would, go along with that reasoning,
especially with so many E. coli and Salmonella outbreaks being reported. Moreover, no farmer would want to take on
the liability of a flour recall or the heartbreak of causing someone's death. Contaminated vegetables affects the whole
industry. The greatest economy cost falls on the farmer, retailer and consumer. The problem for me in 1998 was that
no one seem to understand, or be able to explain, the term fecal coliform and there was little information available on
the internet.

Few people could afford the time, or money, to do the research to discover what EPA and the states were hiding
behind the fecal coliform banner. On the other hand, when they are destroying the value of everything you own, and
thirteen states have enacted food slander laws preventing you from talking about foodborne bacterial poisoning, there
is no choice, especially when the same thing is happening across the country. The biggest heartbreak in my mind was
all these agencies (federal, state, municipal) lying to farmers about the nature of the disease causing organisms they
were hiding under the banner of fecal coliform or coliform. The next biggest heartbreak is when a farmer discovers
he/she has been victimized and the legal system is invoked by the perpetrators to finish destroying his/her assets in an
attempt to cover up the lies.

The top EPA experts (
Alan Rubin, James Smith, Jini Mohanty) and USDA expert (Rufus Chaney), refused to even
discuss, or define, the nature  of fecal coliforms well into 2007. In 2007,
Mark Meckes, who did the original research on
UV light and
antibiotic resistant coliforms released in sludge effluents from sewage treatment plants grudgingly
supplied part of the answer in a series of emails. The first responses where less than candid. He said, "For example,
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."

Later, Meckes' was more forthcoming in identifying the family of
Enterobacteriaceae as total and fecal coliforms. He
said, "The total and fecal coliform groups are commonly used as indicators of fecal pollution.  The total coliform group
consists of several genera of bacteria belonging to the family Enterobacteriaceae.  The historical definition of this
group has been based on the method used for detection (lactose fermentation) rather than on the tenets of systematic
bacteriology.  Accordingly, when the fermentation technique is used, this group is defined as all facultative anaerobic,
gram-negative, non-spore-forming, rod-shaped bacteria that ferment lactose with gas and acid formation within 48 h at
35 degrees C.  The fecal coliform group also consists of several genera of bacteria belonging to the family
Enterobacteriaceae.  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 (specifically EC medium) with gas and acid formation within 24 h at 44.5 degrees C."

The key words are EC medium. EC (E. coli) medium specifically refers to a culture medium used to inhibit the growth of
non-Enterobacteriaceae at 35 degrees C and most Enteobacteriaceae at elevated temperatures. According to Perry
and Hajna's 1944 study "
Further Evaluation of EC Medium for the Isolation of Coliform Bacteria and Eschericbia coli,"  
EC medium was developed for the isolation of coliform bacteria at 37°C and of thermotolerant Escherichia coli at 45.5°
C. They say, "EC medium was found highly specific for Escherichia coli at this temperature." While this may have been
true at one time, this was not true for non-thermotolerant E. coli 0157, which claimed its first apparent Naval laboratory
victim in 1975 and caused the first fast food outbreaks in 1982 at McDonald's stores in Oregon and Michigan.

The studies focusing on environmental strains of bacteria appear to be the basis for the 1981,
federal policy
to spread pathogen contaminated sewage sludge on fruits and vegetables with the implication that
limiting the amount of thermotolerant E. coli would assure its safety. The dogma of thermotolerant E. coli being the only
fecal indicator with any sanitary significances was reinforced in the 1984 study, "
Thermotolerant Non-fecal Source
Klebsiella pneumoniae: Validity of the Fecal Coliform Test in Recreational Waters
S. KANAREK, University of Wisconsin at Madison, stated, "The validity of the currently recognized fecal coliform
standard must be reevaluated for greater specificity and better correlation with the health hazards associated with
environmental pollution. This cannot be properly accomplished until the current guidelines and standards are broken
down to two restrictive groups of thermotolerant bacteria: one group consisting of thermotolerant/fecal source bacteria
measured by
E. Coli densities as discussed by Dufour,10 and a second group consisting of thermotolerant/non-fecal
source bacteria as measured by
Klebsiella, Enterobacter, and Citrobacter densities." http://www.ncbi.nlm.nih.

This dogma in the food and water industries replaced one hundred years of medical science showing that all of these
bacteria cause disease and death in humans at normal mesophilic temperatures. The question that needs to be
answered is, why would these "experts" claim thermotolerant Klebsiella, Enterobacter and Citrobacter are harmless
non-fecal source bacteria when they were some of the first documented disease causing organisms? Moreover, as
mentioned earlier, they are secondary to E. coli as the cause of acute urinary tract infections in women.

In the following three regulatory descriptions, only Texas indicates that
E. coli will actually cause acute intestinal
. A Sánchez-Miralles, Hospital Universitario San Juan de Alicante, explained what that means in the January
2012 study "
Abdominal compartment syndrome and acute intestinal distress syndrome." He states, "Seriously ill
patients frequently present intra-abdominal hypertension (IAH) and abdominal compartment syndrome (ACS) as
complications, and
the associated mortality is very high."

Anointing thermotolerant E. coli as fecal coliform for the regulation was actually a means for states and municipalities
to lower potential liability as Judges do not question regulations. No court would question why there is no indication
temperature is involved in differentiating the types of coliform or that the term  E. coli  only applies to thermophilic
strains. It is hard to see any of this from the EPA and State definitions which imply that E. coli is something other than
the primary pathogenic coliform regardless of the temperature.

According to
  • Coliforms are bacteria that live in the intestines of warm-blooded animals (humans, pets, farm animals,
    and wildlife).
  • Fecal coliform bacteria are a kind of coliform associated with human or animal wastes.
  • Escherichia coli (E. coli) is part of the group of fecal coliforms.
  • In themselves, coliforms generally do not pose a danger to people or animals, but they indicate the
    presence of other disease-causing bacteria, such as those that cause typhoid, dysentery, hepatitis A, and
Could it really be EPA doesn't know the coliform Salmonella causes typhoid or that the coliforms E. coli, Salmonella,
Shigella, etc., causes dysentery as well as other life threatening diseases?

Washington state Department of Health states:
  • 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.

According to the Texas Commission on Environmental Quality (TCEQ):
    Texas has determined from Rules and Regulations for Public Water Systems; Glossary, Water and
    Wastewater Control Engineering; State Source Water Assessment and Protection Programs Guidance;
    Susceptibility Assessment Document, and Title 40 Code of Federal Regulations that the following are
    legal definitions:
  • total Coliform—bacteria that are used as indicators of fecal contaminants in drinking water.
  • fecal coliform—a bacteria used to indicate the presence of other disease-causing organisms.
  • E. coli.—Escherichia coli. A bacteria which can cause acute intestinal distress.
It would appear that even TCEQ had a problem figuring out that E. coli is the fecal coliform. If Texas couldn't figure out
what a fecal coliform is, it is easy to see how a student, and his instructors, could be fooled by his EPA mentors.

EPA and its partners took the lead in spreading this confusing dogma worldwide. Yet, the three confusing descriptions
have absolutely no meaning to the general public or apparently most scientists. If you listen to some food, water and
sewage experts, scientists have been confused for over 100 years about the nature of the coliform group.  However,
that would appear to be convincing proof that scientists didn't know their own temperature was only 37°C (98.6°F). As
an example, since Christiaan Eijkman discovered a thermotolerant stain of E. coli in 1904 at 46°C (114.8°F), it has
been the expert consensus among scientists in food, water and sewage industries that gas production from E. coli
bacteria found at that thermophilic temperature was from humans and other warmblooded animals, hence, the name
fecal coliform.  It sounds silly now, but the scientific consensus was/is that there is a need to inhibit the growth of
pathogenic bacteria before testing for contamination in food or water at a thermophilic temperature.  

In the 1930 study, "
Brown and C. E. Skinner, University of Minnesota at Minneapolis, outlined the inherit confusion with the fecal coliform  
test industry scientists still trade on today. They said, "Although the American Public Health Association standards do
not distinguish between B. coli and B.
aerogenes in the "completed test," there can be little doubt that B. aerogenes
has no value as an index of fecal pollution. --  B. [Escherichia] "
coli from cold blooded animals, practically all B.
aerogenes, (and B. cloacae), Bacterium proteus, and the various fermenting anaerobic rods are said to be completely
inhibited as far as gas production is concerned. -- Also, his results, as well as those of others, show conclusively that
the Eijkman test does eliminate a great many of the positive tests, the origin of which was cold blooded animals. -- 5.
Only B. coli (never
B. aerogenes) was found in human feces. -- Our results indicate that, even if the production of gas
at 46° from glucose broth be a fair index of pollution from feces, the lack of such gas formation does not prove the
absence of pollution."

World Health Organization (WHO)  understands the fallacies in the study, yet, it reinforces the image of scientific
confusion when it states, "The range of non-faecal bacteria represented in the coliform group and the environmental
growth of thermophilic (faecal) coliforms Klebsiella spp. and E. coli (Ashbolt et al. 1997; Camper et al. 1991) have
concerned bacteriologists and sanitary engineers since the 1930s (Committee on Water Supply 1930)."  Yet, WHO still
recommends the thermophilic test for E. coli to assure the safety of drinking water.

In spite of WHO claiming thermophilic E. coli is the most appropriate bacteria to indicate fecal pollution, WHO knows
there is no science to back it up and excludes E. coli 0157 from its definitions because it is not thermophilic . According
to WHO:

    total coliforms are members of genera or species within the family Enterobacteriaceae, capable of growth
    at 37°C, which possess β-galactosidase (HMSO 1989, 1994).

    Faecal indicator: A group of organisms that indicates the presence of faecal contamination, such as
    the bacterial groups thermotolerant coliforms or E. coli. Hence, they only infer that pathogens may
    be present.

    Thermotolerant coliforms: Coliforms that produce acid and gas from lactose at 44.5±0.2°C [112.1°F]
           within 24±2h, also known as faecal coliforms due to their role as faecal indicators.

    Escherichia coli (E. coli): Thermophilic coliforms that produce indole from tryptophan, but also defined now
    as coliforms able to produce β-glucuronidase (although taxonomically up to 10% of
    environmental E. coli may not). Most appropriate group of coliforms to indicate faecal
    pollution from warm-blooded animals

Based on 1990 work "
Temperature Range for Growth of Escherichia coli Serotype 0157:H7 and Selected Coliforms in
E. coli Medium" by Errol V. Raghubeer and Jack R. Matches, Institute for Food Science and Technology, School of
Fisheries, University of Washington at Seattle, Shiga toxin-producing E. coli 0157 would not show up in the tests due to
"the absence of β-glucoronidase activity (9), and the inability to grow at temperatures normally used in most probable
number (MPN) procedures for enumerating fecal coliforms and thermophilic E. coli."

It would appear that none of the industry experts ever consulted with medical experts concerning the low temperature
animal, human, plant, soil and water coli-like bacterial cousins in the family Enterobacteriaceae that also caused
disease and death in humans. Based on the medical literature, it is clear that the industry's scientific experts have
been deliberately misleading us.

According to the definition in
Jawetz, Melnick, & Adelberg's Medical Microbiology, 25e,  "Enteric Gram-Negative Rods
(Enterobacteriaceae): "The Enterobacteriaceae are a large, heterogeneous group of gram-negative rods whose
natural habitat is the intestinal tract of humans and animals. The family includes many genera (
Escherichia, Shigella,
Salmonella, Enterobacter, Klebsiella, Serratia, Proteus, and others). Some enteric organisms, eg, Escherichia coli, are
part of the normal flora and incidentally cause disease, while others, the salmonellae and shigellae, are regularly
pathogenic for humans. The Enterobacteriaceae are facultative anaerobes or aerobes, ferment a wide range of
carbohydrates, possess a complex antigenic structure, and produce a variety of toxins and other virulence factors.
Enterobacteriaceae, enteric gram-negative rods, and enteric bacteria are the terms used in this chapter, but these
bacteria may also be called

The medical profession has known, at least since the 1919 book, "
Modern Surgery, General and Operative" was
published that at the lower temperature, "This bacillus [E. coli] may be responsible for appendicitis, peritonitis,
inflammation of the genito-urinary tract, pneumonia, inflammation of the intestine, leptomeningitis, perineal abscess,
cholangitis, cholecystitis, myelitis, puerperal fever, wound infections and septicemia. It is the cause of many abscesses
about the intestine and responsible for many ischiorectal abscess. From the pus of an appendicitis abscess we may
perhaps obtain culture of Escherich's bacillus, but usually find also
streptococci or staphylococci, and sometimes
pneumococi. Colon bacilli introduced into the system by tainted food may be responsible for epidemic pneumonia . A
few years ago there was such an epidemic in Middlesbrough, England (Oliver, in "Brit. Med. Jour." April 30, 1910)

All of these diseases are still caused by the plain old generic E. coli in your gut. Currently, according to Dr. Tarun
Madappa (Medscape Nov 15, 2011), E. coli is the leading cause of both community-acquired and health care acquired
Urinary Tract Infections (UTI). He Said, "Up to 50% of females eventually experience at least one episode of UTI. E coli
causes 12-50% of nosocomial infections and 4% of cases of diarrheal disease. --  E coli causes a wide range of UTIs,
including uncomplicated urethritis/cystitis, symptomatic cystitis, pyelonephritis, acute prostatitis, prostatic abscess, and
urosepsis --- Complicated UTI and pyelonephritis are observed in elderly patients with structural abnormalities or
obstruction such as prostatic hypertrophy or neurogenic bladders or in patients with urinary catheters. -- The
recurrence rate after a first E coli infection is 44% over 12 months. -- E coli neonatal meningitis [sepsis] carries a
mortality rate of 8%, and most survivors have neurological or developmental abnormalities. -- E coli bacteremia
precedes pneumonia and is usually due to another focus of E coli infection in the urinary or GI tract. -- E coli intra-
abdominal infections often result from a perforated viscus (eg, appendix, diverticulum) or may be associated with intra-
abdominal abscess, cholecystitis, and ascending cholangitis. Patients with diabetes mellitus are also at high risk of
developing pylephlebitis of the portal vein and liver abscesses. -- Cholecystitis and cholangitis result from obstruction
of the biliary system from biliary stone or sludge, leading to stagnation and bacterial growth from the papilla or portal
circulation. --  E coli infections include septic arthritis, endophthalmitis, suppurative thyroiditis, sinusitis, osteomyelitis,
endocarditis, and skin and soft-tissue infections (especially in patients with diabetes). -- The systemic reaction to
endotoxin (cytokines) or lipopolysaccharides can lead to disseminated intravascular coagulation and death."

The End Result of Dumbing Down Science

Federal and state agencies claim they are permitting the recycling of "treated sludge" (biosolids) and "treated sewage
effluent" (reclaimed water) when they are really recycling pathogenic disease causing organisms under the pseudonym
coliform or fecal coliforms. However, it was shocking to find the Department of Environmental Health, College of
Medicine, University of Cincinnati, approved a 2006 Masters of Science Thesis in Epidemiology that "suggests
prolonged exposure to fecal coliform may actually be protective against infections." It was especially shocking to find
the names of three top EPA experts involved as mentors and one as an advisor.

The title of the Thesis was "
Association of Fecal Coliform Levels in Kansas Streams and Prevalence of Infection with
Escherichia coli."  The Thesis Committee consisted of two professors of Epidemiology and Biostatistics (Kim Dietrich &
M. B. Rao) and an Ecologist (Brent Johnson) at the National Exposure Research Laboratory of United States
Environmental Protection Agency  who approved the statement by Adam Haas (now an Environmental Scientist with an
EPA contractor, Computer Sciences Corporation)  who said, "
The negative association with E. Coli suggest that
prolonged exposure to high fecal coliform levels may be protective against infection. Other studies have
indicated that previous exposure to E. Coli, may result in partial resistance or complete immunity to
subsequent infection

Since thermophilic E. coli (fecal coliform) are only a very small fraction of mesophilic E. coli pathogens, it really is
negatively associated with prevalence of E. Coli. However, the study is actually very misleading as it compared fecal
coliforms levels to the extremely small percentage of Shiga toxin-producing E. coli infections reported in Kansas.  As
noted by Errol V. Raghubeer and Jack R. Matches, Shiga toxin-producing E. coli 0157 does not show growth at the
temperature used to detect fecal coliforms so there is no basis for comparison. Furthermore, the Shiga toxin-producing
E. coli infections would need to be fairly serious to be reportable in Kansas  as some laboratories do not routinely test
for it, unless requested to do so. While some people show no effect from an infection, for those with a defective
immune sysytem the complications can be serious such as severe kidney complications like  hemorrhagic colitis,
Hemolytic Uremic Syndrome (HUS), or postdiarrheal thrombotic thrombocytopenic purpura (TTP) which can occur in up
to 10% of cases. Since the Thesis concerned confined animal feeding operations a more relevant comparison would
have been between fecal coliforms and other reportable disease organisms EPA has associated with CAFO',
especially,  the waterborne zoonotic pathogen
Chlamydia trachomatis.

To be fair, Masters Degrees are expensive, time consuming and students depend on their Thesis Committee and
mentors with Ph.D's for honest guidance.  It is unlikely that the student, mentored by four senior water environmental
scientists with an agenda to create new dogma, such as Ken M. Fritz and Brent R. Johnson authors of the "
Operations Manual for Assessing the Hydrologic Permanence and Ecological Condition of Headwater Streams" as well
as Florence Fulk, Acting Director Ecological Exposure Research Division, and Randy Bruins, research project leader
for the Midwest Ecosystem Services Research Program in EPA's Office of Research and Development, even knew the
real nature of thermotolerant fecal coliform. It is also very likely that the two professors of Epidemiology and
Biostatistics, who sat on the Thesis Committee had no idea either. However, One of the student's mentors, Dr. Brent
Johnson, Ph.D., Ecologist, National Exposure Research Laboratory, was on the Committee to guide the professors with
the official EPA educational program definition: "Fecal coliform are a group of bacteria which, as their name suggests,
are largely associated with fecal contamination. Defined by their method of detection, fecal coliform include any
bacteria that ferment lactose to produce acid and gas at a temperature of 44.5°C [112.1°F]  within 24 hours. Most
fecal coliform are not pathogenic, but beneficial to their host. They are one of many groups of organisms that live in
the intestinal tract of animals, including humans, where they aid in the digestion of food and recovery of nutrients.--
Fecal coliform are widely used as an indicator of pollution because they are directly proportional to fecal wastes,
present in high numbers, and easier to quantify than pathogens. Also, their low pathogenicity makes the fecal coliform
group safer to analyze as opposed to measuring pathogens directly."  

Actually, we do not know if thermotolerant E. coli is beneficial to their host, since human blood coagulates at an internal
temperature 42.5°C  (108.5° F) and -- you die. We do know that when E. coli breeches the gut barrier it becomes a
pathogen as noted above. Moreover, the
International Escherichia and Klebsiella Centre (WHO) has a collection of
approximately 60,000 E. coli strains, most of which are clinical isolates with the following characteristics:
    VTEC: Vero cytotoxin producing E. coli,
    EHEC: Enterohaemorrhagic E. coli (sub-group of VTEC associated with bloody diarrhoea) [0157]
    EPEC: Enteropathogenic E. coli
    EIEC: Enteroinvasive E. coli
    A/EEC: Attaching and effacing E. coli
    ETEC: Enterotoxigenic E. coli
    EAggEC: Enteroaggregative E. coli.
    DAEC: Diffusely Adherent E. coli
    ExPEC: Extraintestinal pathogenic E. coli
    UPEC: Uropathogenic E. coli
Any, or all, of the above clinical characteristics may be associated with bacteria in fecal material. However, all of them
may not ferment lactose to produce acid and gas at a temperature of 44.5C within 24 hours, therefore, they can not be
classified as fecal coliform.

There is little doubt that thermophilic E. coli (fecal coliform), if present, is a guaranteed indicator of pathogen
contaminated manure  and sewage sludge disposed of on agricultural land impacting surface water as well as ground
water.  Unfortunately, the  absence of thermophilic E. coli does not guarantee the absence of E. coli, 0157, or any
other mesophilic pathogen.

As an example, in 2006, Kansas only listed 16 impaired waters attributed to either biological contamination or
E. coli.  
The 2006 Summary  of
REPORTABLE INFECTIOUS DISEASES IN KANSAS caused by pathogens states, "Of the 25
cases of diarrhea--causing E. coli reported in Kansas during 2006, 19 (76%) were caused by E. coli O157:H7. The
remaining cases were  attributed to other STEC strains." On the other hand, the enteric coliforms
Salmonella and
Shigella were 20 times greater (507 cases) than those of E. coli 0157. The non-coliform Campylobacter  accounted for
316 cases and invasive
streptococcus  involved 231 cases in 2005 which dropped to 122 in 2006 was also quite high.  
The waterborne bacterial pathogen
Chlamydia trachomatis was exceptional high at 7,832 cases. That was a dramatic
increase from 1997's 4,698 cases. There were also 82 active
Tuberculosis cases with 3,074 latent infections.

In 2010, the total  number of impaired waters in Kansas was 1,387. Out of 3,045 listed causes of impairment, 130 water
sediments  were listed due to contamination by E. coli contamination.That is 8 times more water impacted areas by E.
coli than in 2006.  By 2009, the number of
E.coli infections had more than doubled to "54 cases of Shiga toxin-
producing  Escherichia coli."  
Salmonella and Shigella was now 24 times greater (612 cases) than those of E. coli  in
Campylobacter also increased to 362  cases in 2009.  There were 143 cases of  invasive streptococcus in
2009.  Thirty-nine cases were Group A Streptococcal (GAS) Diseases.  According to CDC, "Two of the most severe,
but least  common, forms of invasive GAS disease are necrotizing fasciitis and streptococcal toxic shock syndrome.
Necrotizing  fasciitis (occasionally described by the media as "the flesh-eating bacteria") is a rapidly progressive
disease which  destroys muscles, fat, and skin tissue. Streptococcal toxic shock syndrome (STSS) results in a rapid
drop in blood  pressure and organs (e.g., kidney, liver, lungs) to fail." There was a dramatic increase in waterborne
Chlamydia trachomatis infections to 10,527 cases. Active Tuberculosis cases dropped to 64, while latent infections
dropped to 1,927 cases.

Chlamydia is a strange little bug (bacteria formerly thought to be a virus because it has no cell wall) associated with
CAFO waste and sewage sludge. It is generally misunderstood to mean that it is a disease organism transmitted by
sexual activity, rather than simply being infectious through the sex organs as well as eyes, noses and mouth. Men,
women and children are at risk.  Chlamydia may be spread by exposure to contaminated water, food, air or by vectors
such as flies and mosquitoes. It is the leading cause of blindness worldwide and affects many organs and may cause
death if not treated. It is a major health risk on the farm from infected animals.

According to The National Agricultural Law Center's 2002 article "
The EPA’s Proposed CAFO Regulations
Fall Short of Ensuring the Integrity of Our Nation’s Waters, Pathogens such as bacteria and viruses that cause
diseases are also problems associated with CAFO waste. Pathogens are the leading cause of the impairment of
estuaries and the second leading cause of the impairment of rivers and streams. 56 They can cause serious health
problems in both humans and animals. Some of the organisms that may cause diseases include
salmonella, listeria,
vibrio, brucella, cryptosporidium, coxiella, chlamydia, and mycoplasma. 57 In fact, according to the EPA, [0]ver 150
pathogens found in livestock manure are associated with risks to humans. 58 These diseases are transmitted by
drinking contaminated water, eating shellfish, contact through recreational activity, or by insects such as flies and

As noted earlier, the 1981 federal policy promoted the spreading of all of these bacteria, viruses, parasites and many
more "sexually transmitted organisms" as well as organisms not yet identified to be dumped on agricultural land, home
lawns and released to surface water with little or no oversight in sewage "products".
CDC only tracks 31 known
foodborne pathogens. However, for 80% of foodborne illnesses, it just has no idea what they may be.

All pathogens go through sewage treatment plants and many of them find there way through drinking water treatment
plants to your bath and drinking water. It seems obvious that the most pathogen free water would be found where the
most political and regulatory power is concentrated, in Washington DC. It is also where the least amount possible of
information is provided acknowledging the water could be unsafe.  Below is the simple warning given by the
Washington DC Water and Sewer Authority   (Jan 2012). While the Water and Sewage Authority claims coliforms are
not harmful, it encourages children and the elderly to consult with medical professionals concerning extra precautions
needed to prevent infections from the coliforms contaminating the system..  

    "DC WASA collects over 200 samples monthly throughout the District and analyzes for coliform
    bacteria. The test indicates whether any coliform are present in the sample. Most coliform bacteria
    are not harmful to ingest (your intestines contain coliform that aid in digestion). EPA requires testing
    for coliforms because they can indicate the potential presence of more harmful microorganisms. If
    DC WASA detects coliform, vigorous follow-up sampling and testing is immediately conducted to
    ensure no harmful microorganisms are present. --  However, immune compromised people are at a
    greater risk in developing illness. WASA encourages immune compromised individuals to consult
    with their doctor regarding extra precautions to avoid infection."

Would an epidemiologist who believes fecal coliforms prevent infections find infected individuals exposed to this
pathogenic contamination in DC water or would they blame the cook and call it a foodborne infection?

Actually while the coliform test show DC water not in violation of the regulations and might be relatively safe. The test
doesn't offer any assurance of safety due to the number of failed test for Enterobacteriacea. Moreover, as an example,
December 6, 1993, water-treatment plant operators in the District of Columbia (DC) had a filtering problem. Two
days later, on December 8th, it actually issued a boil water order. In a very limited survey, epidemiologist could not
establish an outbreak actually occurred. On the other hand, this followed the April 1993 filter failure at one of
Milwaukee's drinking water treatment plants which allowed cryptosporidium to enter the system. The problem was not
noticed for days until a lot of people started seeking medical treatment. Over 400,000 people were effected with over
4,400 hospitalized. Various estimates for those killed ranged from a few to over 400.  However, we may never know the
actual number.  We do know immune compromised people did not fair well. According to
Dr. Ian Gilson, "One-hundred-
and-three people with HIV and AIDS eventually died because of the contamination."  It took four years for CDC to
publish the data on the outbreak confirming the cryptosporidium was of human origin and
it would not infect animals.
For some reason the media never picked up on the CDC study and Milwaukee is still blaming animals.

Currently, a
ccording to EPA, "approximately 4 percent of all public water systems are considered serious violators."  
That is 6,200 serious violators out of approximately 155,000 public water systems in the United States. It is little wonder
Congress wants to do away with the health care safety net for the poor who are most exposed through drinking water.

The real scary part about these coliforms is found in CDC's March 20, 2009, "
Morbidity and Mortality Weekly Report"
(MMWR) "
Guidance for Control of Infections with Carbapenem-Resistant or Carbapenemase-Producing
Enterobacteriaceae in Acute Care Facilities." CDC states, "Infection with carbapenem-resistant Enterobacteriaceae
(CRE) or carbapenemase-producing Enterobacteriaceae is emerging as an important challenge in health-care settings
(1). Currently, carbapenem-resistant
Klebsiella pneumoniae (CRKP) is the species of CRE most commonly
encountered in the United States. CRKP is resistant to almost all available antimicrobial agents, and infections with
CRKP have been associated with high rates of morbidity and mortality, particularly among persons with prolonged
hospitalization and those who are critically ill and exposed to invasive devices (e.g., ventilators or central venous
catheters). -- Since first described in North Carolina in 1999, CRKP has been identified in 24 states and is recovered
routinely in certain hospitals in New York and New Jersey (3). Analysis of 2007 data regarding health-care--associated
infections reported to CDC indicated that 8% of all Klebsiella isolates were CRKP, compared with fewer than 1% in
2000 (CDC, unpublished data, 2008). CRKP poses significant treatment challenges, and CRKP infections have been
associated with increased mortality, length of stay, and increased cost (4). -- Acute care facilities should establish a
protocol, in conjunction with CLSI guidelines, to detect nonsusceptibility and carbapenemase production in
Enterobacteriaceae, particularly
Klebsiella spp. and Escherichia coli, and immediately alert epidemiology and infection
control staff members if identified. "

Antibiotic resistant contaminated sludge dumped on farms and CAFOs manure may be the common denominator for
the spreading of these antibiotic resistant disease organisms. It is interesting to note that New York City and New
Jersey ship much of their pathogen contaminated sludge out of state to  destinations such Florida, Texas, Colorado
and Pennsylvania. Once a contractor has control of the sludge it may end up anywhere from Texas to Colorado.
Mebane, North Carolina is an example of an area receiving sludge from unknown sources. In 2006, the small City of
Burlington received a seven day permit to dispose of sludge on a Mebane farm. However, the trucks, back to back,
kept rolling six and a half days a week for 53 days. Folks became sick, yet, no epidemiologist was given permission to
investigate even though the county did appropriate money for the study. The problem is that environmental
departments who permit this deadly nonsense have more statutory power than health departments and will not
approve an investigation.

Environmental departments know the danger of releasing antibiotic resistant coliform contaminated sludge into the
environment. Thirty years ago
EPA's Mark Meckes did the research on UV disinfection, which showed that a greater
percentage of antibiotic resistant coliforms were being released from sewage treatment plants in sludge effluents than
entered the treatment plant. Other studies have verified Mecks findings that sewage effluents released to surface
water are contaminated with antibiotic resistant pathogens. Yet, today that information is still being ignored by top
scientific experts researching and/or promoting sewage sludge as a fertilizer and sewage effluent for irrigation as well
as "Toilet to Tap" projects. Never mind that they end up in drinking water.

In the 2011 study, "
The role of drinking water in the transmission of antimicrobial-resistant E. coli", B. L. Coleman, et
al., Mount Sinai Hospital at Toronto, said, "To determine whether drinking water contaminated with antimicrobial-
resistant E. coli is associated with the carriage of resistant E. coli, selected households sending water samples to
Ontario and Alberta laboratories in 2005–2006 were asked to participate in a cross-sectional study. Household
members aged ≥12 years were asked to complete a questionnaire and to submit a rectal swab. In 878 individuals, 41%
carried a resistant strain of E. coli and 28% carried a multidrug-resistant strain. The risk of carriage of resistant E. coli
was 1·26 times higher for users of water contaminated with resistant E. coli. Other risk factors included international
travel [prevalence ratio (PR) 1·33], having a child in nappies (PR 1·33), being male (PR 1·33), and frequent handling
of raw red meats (PR 1·10). Protecting private water sources (e.g. by improving systems to test and treat them) may
help slow the emergence of antimicrobial resistance in E. coli."

Antibiotic resistant bacteria moving from sewage treatment plants and through the drinking water treatment plants into
the drinking water system is a very real and serious threat to public health. Once the antibiotic resistant
Enterobacteriaceae enter the public water system there is not only the potential for immediate harm, but they create
biofilms in the pipes which keep building until they flake off or mature and spew bacteria into the home water system
where they may cause disease or worse.  Unfortunately, there are also lot more dangerous bacteria than coliform
building in the biofilms including
MRSA, streptococcus, Listeria, Legionella, etc.

While some people may be infected carriers of coliform such as Salmonella -- think Typhoid Mary -- these coliform
bacteria as well as others may create biofilms in different areas of the human body causing chronic infection and/or
inflammation. According to the
Montana State University experts,  "Biofilms are implicated in otitis media, the most
common acute ear infection in children in the U.S. Other diseases in which biofilms play a role include bacterial
endocarditis (infection of the inner surface of the heart and its valves), cystic fibrosis (a chronic disorder resulting in
increased susceptibility to serious lung infection), and Legionnaire's disease (an acute respiratory infection resulting
from the aspiration of clumps of Legionnella biofilms detached from air and water heating/cooling and distribution
systems). Biofilms may also be responsible for a wide variety of nosocomial (hospital-acquired) infections. Sources of
biofilm-related infections can include the surfaces of catheters, medical implants, wound dressings, or other types of
medical devices." For more information view the six-minute video clip at
v=lpI4WCM_9pM&feature=youtu.be: "a four minute montage of clips from early interviews with biofilm researchers, then
a 3D animation showing the "life cycle" of bacterial biofilm -- including its dispersal into the bloodstream." Biofilms are
also involved in skeletal infections or osteomyelitis.

Knowing that treatment processes can not keep these antibiotic resistant pathogens out of drinking water systems and
that pathogenic biofilms build up in drinking water systems pipes,  the industry still pushes to contaminate the systems
with "treated sewage recycled water", better known as "toilet to tap".  What we also have to consider are biofilms
building up in pipes used to carry  "treated sewage recycled water" for irrigating lettuce, spinach and other crops such
as 12,000 acres in the Salinas Valley of California and other places as well as lawns. Scientists only recently
acknowledged in the California media that biofilms build up on food crops and they are hard to remove. According to
Deborah Schoch writing in the January 30, 2012 edition of the Las Angeles Times, "You have this gooey mass, like
frosting on top of a cantaloupe surface or a leaf surface," said Trevor Suslow, a UC Davis food safety researcher.
"They're hard to penetrate by antimicrobials. They're glued on pretty tightly."

This is not really new information. The Institute of Food Technologists (IFT) issued a Scientific Status Summary on
quorum sensing in biofilm formation in 2009 titled, "
Biofilms: A Threat to Food Safety". It said, "Through cell-to-cell
signaling known as quorum sensing, bacterial cells coordinate biofilm formation. Biofilms enable bacteria to survive
unpredictable environmental stressors such as temperature changes, desiccation, ultraviolet rays, and so on. --
Besides causing tooth decay, slippery rock surfaces, and contaminated water, these colonies of microbes may also
cause persistent low-level food contamination (Annous et al., 2009). In fact, biofilms containing human pathogens can
impair food safety. Capable of surviving for extended periods in water, animal manure, and various agricultural soils,
human pathogens can attach to and colonize the surfaces of plants (Annous et al., 2009). Once they attach to plant
surfaces, human pathogens can and often do form biofilms on plant tissues. Because biofilms are hearty and not
easily removed with simple washing techniques, foodborne illnesses associated with fresh fruits and vegetables have
increased dramatically over the past 30 years (Fett and Cooke, 2003; Sivapalasingam et al., 2004). In fact, up to 80%
of bacteria on plant surfaces constitute biofilms (Lindow and Brandl, 2003). More than likely, the bacteria form biofilms
to survive the unpredictable environmental stressors on the plant surface: temperature changes, desiccation,
ultraviolet rays, etc. Three produce items—cantaloupe melons, apples, and leafy greens—have been identified as
biofilm carriers as well as recurrent culprits for foodborne illness outbreaks."

Most people think food and waterborne infections are easily resolved with antibiotic treatment. While that may be true
for most of the population, for some, infections can have a heavy economic cost. According to
CDC, "For Shiga toxin-
producing Escherichia coli O157 (0157 STEC) infections -- The average cost per case varied greatly by severity of
illness, ranging from $26 for an individual who did not obtain medical care to $6.2 million for a patient who died from
hemolytic uremic syndrome. A former FDA economist shows how expensive some infections are on average, if you
survive without severe chronic health damage.
Dr. RobertScharff, Georgetown University, states, "Acute foodborne
illnesses cost the United States an estimated $152 billion per year in healthcare, workplace and other economic
losses." Yet, the study does not really examine the total cost for coliform superbugs.

This is an example of the average costs given for just four acute coliform infections.
    E. coli O157:H7                         $14,838.00
    Salmonella, nontyphoidal            $9,146.00
    Shigella spp.                               $7,092.00
    Yersinia enterocolitica                 $7,227.00

It gets worse for four acute non-coliform infections
    Brucella spp                               $70,698.00
    Listeria monocytogenes        $1,695,143.00
    Vibrio vulnificus                     $3,045,726.00
    Vibrio, other                               $21,810.00


Researchers must know, if they want  funds for research on manure, sludge and reclaimed water, they will follow the
federal agencies policies and definitions laid out by the guiding authorities, which puts public health at risk. If you eat
food, drink water and need health care, it is time to take a close look at the politicians who take the moral high ground
and put our health at risk.
Mandatory reporting of infectious
coliform bacteria and disease