It would appear that part of the 1994 EPA -WEF PR campaign to change public perception about the danger
of using pathogenic disease contaminated sewage sludge by changing the name to Biosolids, included an
even more deadly change of names to fool the public. It appears EPA dropped the PUBLIC HEALTH
DEPARTMENT STANDARD adopted in 1914 to detect the 12 enteric bacteria in a coliform which indicated
the presence of sewage contamination in water and food. In place of the 12 pathogenic enteric bacteria,
EPA substituted a group of Heterotrophic bacteria on which little research has been done, except for a
couple of pathogenic bacteria they didn't think would be noticed. Now the public is being told that this new
group of bacteria called coliform do not cause disease in humans. No where, is the deception more evident
than in California. Fortunately, California senator Florez is working  to change this sad situation.

Generally,  the term colony-forming unit (CFU) is used to describe the cell division of a single bacteria into a
colony as it divides every 20 - 30 minutes during the 48 hour test. However, a coliform (FDA) is composed of
12 human disease causing pathogenic enteric bacteria that pass through the gut: ESCHERICHIA COLI,

When one or  more members of  coliform pass through the gut, they becomes fecal coliform,
[primarily E. coli] indicating sewage contamination. Yet, EPA and its partner, WEF, wave a
sludge policy in
our face to
prove biosolids is safe and then claim sludge - biosolids with  approximately 1000 CFU of fecal
coliform [ E. coli]  per gram (1000/1 ml most probable number) (exceptional quality Class A) is perfectly safe
for food crops and direct human contact on your lawn, garden, park and school yard. If the EPA  maximum
safe  human contact level for fecal coliform in water is 6 cfu per gram, why would fecal coliform at1,000 cfu
per gram be safe for your child to contact  playing in a park or on a school yard or your lawn?

In 1892, Shardinger proposed the use of E. coli as an indicator of fecal contamination. This was based on
the premise that E. coli is abundant in human and animal feces and not usually found in other niches.
Furthermore, since E. coli could be easily detected by its ability to ferment glucose (later changed to
lactose), it was easier to isolate than known gastrointestinal pathogens. Hence, the presence of E. coli in
food or water became accepted as indicative of recent fecal contamination and the possible presence of
frank pathogens [infect normal as well as people with poor immune systems] .

Although the concept of using E. coli as an indirect indicator of health risk was sound, it was complicated in
practice, due to the presence of other enteric bacteria like Citrobacter, Klebsiella and Enterobacter that can
also ferment lactose and are similar to E. coli in phenotypic characteristics, so that they are not easily
distinguished. As a result, the term "coliform" was coined to describe this group of
enteric bacteria which
are incubated at 35 C. The termotolerant E. is incubated at 44.5 C

Coliform is not a taxonomic classification but rather a working definition used to describe a group of Gram-
negative, facultative anaerobic rod-shaped bacteria that ferments lactose to produce acid and gas within 48
h at 35°C. In 1914, the U.S. Public Health Service adopted the enumeration of coliforms as a more
convenient standard of sanitary significance.


Citrobacter: C. freundii is suspected to cause diarrhea and possibly extraintestinal infections. C. diversus
has been linked to a few cases of meningitis in newborns.

Edwardsiella tarda:  E. tarda produces hydrogen sulfide. This bacterium is usually found in aquatic animals
and reptiles. However, it has been known to cause gastroenteritis and wound infections in humans.

Enterobacter: several species cause opportunistic infections of the urinary tract as well as other parts of the
body.E. aerogenes and E. cloacae are two such pathogens that do not cause diarrhea, but that are
sometimes associated with urinary tract and respiratory tract infections.

ESCHERICHIA COLI: Besides being the number one cause of human urinary tract infections, E. coli has
been linked to diseases in just about every other part of the body. Pneumonia, meningitis, and traveler's
diarrhea are among the many illnesses that pathogenic strains of E. coli can cause. Pathogenic strains of E.
coli can cause severe cases of diarrhea in all age groups by producing a powerful endotoxin. [Central
America Shigella strain Toxin] Treating E. coli infections with antibiotics may actually place the patient in
severe shock which could possibly lead to death. This is due to the fact that more of the bacterium's toxin is
released when the cell dies.

Klebsiella:  Klebsiella's pathogenicity can be attributed to its production of a heat-stable enterotoxin.  K.
pneumoniae is second only to E. coli as a urinary tract pathogen. Klebsiella infections are encountered far
more often now than in the past. This is probably due to the bacterium's antibiotic resistance properties.
Klebsiella species may contain resistance plasmids (R-plasmids) which confer resistance to such antibiotics
as ampicillin and carbenicillin. To make matters worse, the R-plasmids can be transferred to other enteric
bacteria not necessarily of the same species.

Morganella morganii  can cause urinary tract and wound infections, as well as diarrhea.

Providencia species have been associated with nosocomial (hospital acquired) urinary tract infections.
P. alcalifaciens, has been associated with some cases of diarrhea in children.

Proteus,  can cause urinary tract infections and hospital-acquired infections.   P.mirabilis, a cause of wound
and urinary tract infections. most strains of P. mirabilis are sensitive to ampicillin and cephalosporins.  P.
vulgaris is not sensitive to these antibiotics.

Salmonella: S. typhimurium and S. enteritidis are the two leading causes of salmonellosis (inflammation of
the intestine caused by Salmonella).  S. typhi is unique because it is only carried by humans. This
intracellular parasite can cause typhoid fever (enteric fever) which is characterized by fever, diarrhea, and
inflammation of the infected organs.

Serratia genus were once known as harmless organisms that produced a characteristic red pigment. Today,
Serratia marcescens is considered a harmful human pathogen which has been known to cause urinary tract
infections, wound infections, and pneumonia. Serratia bacteria also have many antibiotic resistance
properties which may become important if the incidence of Serratia infections dramatically increases

Shigella is also an invasive pathogen which can be recovered from the bloody stool of an infected host.

Invasive pathogens colonize the host's tissues
as opposed to growing on tissue surfaces.

Yersinia genus: Y. enterocolitica and Y. pestis. Y. enterocolitica is the most often encountered species of
Yersinia in the lab. This bacterium is an invasive pathogen which can penetrate the gut lining and enter the
lymphatic system and the blood. Infection, which is usually through ingestion of contaminated foods, can
cause a severe intestinal inflammation called yersiniosis. Release of its enterotoxin can cause severe pain
similar to that found in patients with appendicitis.

Y. pestis is included here because it causes the bubonic, pneumonic, and septicemic plagues. Human
contraction of bubonic plague is usually through flea bites. Once inside the body, Y. pestis releases a toxin
which inhibits electron transport chain function. Swelling of the lymph nodes, skin blotches, and dilerium are
sometimes observed within a few days of infection. Untreated infections usually result in death within a week
of initial infection.

EPA, god bless them, uses outside scientists as sources for scientific studies in developing its regulations.
Since the scientific consenus is that colifom bacteria do not cause diseases in human how can we blame
those poor EPA employees if we contact an illness or die from being exposed to pahtogenic disease
organisms allowed in the regulations for reclaimed water and biosolids used on food crops, lawns, parks,
play grounds and school yards? After all, its not the regulation writers fault scientist didn't give him the
correct information.

As an example, it turns out, water may be so contaminted with Heterotrophic bacteria, the simple Standard
test for coliform can not be done correctly without wasting taxpayer money for a proper lab test to identfy E.
coli.  But that's not EPA's fault, is it? And somebody somewhere said
coliform bacteria do not cause
disease in humans
so it must be the gospel truth.

Now we know were all the scientist went, if this is what they teach in Universities.


Coliforms are bacteria that live and replicate in the intestinal tract of humans and other warm-blooded
animals, and thus they are a normal constituent of fecal material. In general,
coliform bacteria do not
cause disease in humans
. Coliforms are inactivated, or destroyed, to varying degrees by water and
wastewater treatment processes. It
was believed for many years that the processes that inactivate coliforms
also inactivate any pathogenic (disease-causing) microorganisms that were present in the water or
wastewater. [Now they know better, coliforms are inactivated at low levels of disinfection]

Thus, coliforms have been used as indicators for the presence of pathogenic microorganisms. In other
words, if coliforms are detected in water, it is assumed that pathogenic microorganisms may also be
present, and steps must be taken to protect the public health.  [colliforms are pathogens]

HPC populations greater then 500-1000 cfu/mL in drinking water can interfere with
coliform/E. coli [fecal
analysis by lactose-based methods, which include the membrane-filtration method. Klebsiella,
Pseudomonas, and Aeromonas cannot be considered opportunistic pathogens
when found in drinking
water, since there is no clinical or epidemiological evidence to support this designation.  [all pathogens]

HPC Bacteria Issues and Their Effect on the POU Industry: Analysis
by Peter S. Cartwright, P.E., CWS-VI
Arguably, the leading microbiologist in the point-of-use/point-of-entry (POU/POE) segment of the water
treatment industry, University of Arizona professor Charles Gerba, is currently investigating these issues.
(Gerba presented his most recent findings at the WQA Las Vegas convention in March 2003). He has
indicated that the inhibitory effect of HPC bacteria on pathogenic bacteria is so significant that HPC bacteria
proliferation shouldn't be discouraged. Obviously, for semiconductor rinsing, pharmaceutical manufacturing,
hemodialysis and other applications requiring microorganism-free water, this isn't an optionラbut, for most
drinking water uses and many other applications, it is. [HPC interfere with coliform/E. coli test]

There is an urgent need for taxonomic studies on HPC bacteria in order to improve the ability to identify
them and further our understanding of any role, if any, they may have in the epidemiology of gastrointestinal
disease. The strains collected in this study could form the basis of such studies.

Health Stream Conference Report - Issue 26 June 2002

Heterotrophic Plate Count Bacteria in Drinking Water - Public Health Implications?
22-24 April 2002, Geneva, Switzerland.
By Dr David Cunliffe, Department of Human Services, South Australia.

Heterotrophs are defined as microorganisms including bacteria and fungi that require organic carbon for

Numbers of HPC in foods are several orders of magnitude higher than those in drinking water and there is
no evidence, in the absence of specific pathogens, that this general group of organisms represents a
human health risk.

So-called opportunistic pathogens that may be recovered in HPC testing include strains of Pseudomonas
aeruginosa, Aeromonas, Klebsiella and Acinetobacter [all pathogens]

Improvement of HPC methods will not change the status that tests for these organisms as a group lacks
public health significance.

Are these guys kidding? Are these really the scientists that advise EPA? Don't they even take a few minutes
to use the internet?

FDA  Bad Bug Book

Aeromonas hydrophila is a species of bacterium that is present in all freshwater environments and in
brackish water. Some strains of A. hydrophila are capable of causing illness in fish and amphibians as well
as in humans who may acquire infections through open wounds or by ingestion of a sufficient number of the
organisms in food or water.

A. caviae and A. sobria also may cause enteritis in anyone or septicemia in immunocompromised persons or
those with malignancies.

Two distinct types of
gastroenteritis have been associated with A. hydrophila: a cholera-like illness with a
watery (rice and water) diarrhea and a dysenteric illness characterized by loose stools containing blood and
mucus. The infectious dose of this organism is unknown, but SCUBA divers who have ingested small
amounts of water have become ill, and A. hydrophila has isolated from their stools.

A general infection in which the organisms spread throughout the body has been observed in individuals
with underlying illness (septicemia).

Aeromonas species are associated with gastroenteritis and with wound infections, particularly wounds
incurred in outdoor settings. On May 1, 1988, isolates of Aeromonas became reportable in California, the
first state to mandate reporting of isolates of and infections with these organisms. From May 1, 1988,
through April 30, 1989, clinicians and clinical laboratories in California reported 225 Aeromonas isolates
from 219 patients. Cases were reported on Confidential Morbidity Report cards to local health departments,
which then conducted case investigations and forwarded their reports to the California Department of Health

Klebsiella:  Klebsiella's pathogenicity can be attributed to its production of a heat-stable enterotoxin.  K.
pneumoniae is second only to E. coli as a urinary tract pathogen. Klebsiella infections are encountered far
more often now than in the past. This is probably due to the bacterium's antibiotic resistance properties.
Klebsiella species may contain resistance plasmids (R-plasmids) which confer resistance to such antibiotics
as ampicillin and carbenicillin. To make matters worse, the R-plasmids can be transferred to other enteric
bacteria not necessarily of the same species.

Acinetobacter species: A. baumannii can be linked to many hospital acquired infections including skin and
wound infections, pneumonia, and meningitis. A. lwoffi, in particular, is responsible for most cases of
meningitis caused by Acinetobacter.

PSEUDOMONAS:  These bacteria are resistant to most antibiotics and they are capable of surviving in
conditions that few other organisms can tolerate. These pathogens colonize the lungs of cystic fibrosis
patients, increasing the mortality rate of individuals with the disease. Infection can occur at many sites and
can lead to urinary tract infections, sepsis, pneumonia, pharyngitis, and a lot of other problems.
Pseudomonas aeruginosa;  pathogenicity involves several toxins and chemicals which the bacterium
secretes upon infection. The lipopolysaccharide layer helps the cell adhere to host tissues and prevents
leukocytes from ingesting and lysing the organism. Lipases and exotoxins then procede to destroy host cell
tissue which then leads to the complications associated with infection. Burkholderia (Pseudomonas) cepacia
is an opportunistic pathogen of cystic fibrosis patients. Stenotrophomonas maltophila (formerly known as
Xanthomonas maltophila) is very similar to the Pseudomonads. S. maltophila also harbors significant
resistance to many antibiotics considered effective for treating Pseudomonas infections

Doesn't it seem like EPA  really was led astray from science by the misleading information furnished by
University scientists and others?   EPA is no longer using the PUBLIC HEALTH DEPARTMENT STANDARD

Part “141.74(c)(3)(i) The residual disinfectant concentration must be measured at least at the same points
in the distribution system and at the same time as total coliforms are sampled, as specified in Sec. 141.21,
except that the State may allow a public water system which uses both a surface water source or a ground
water source under direct influence of surface water, and a ground water source to take disinfectant
residual samples at points other than the total coliform sampling points if the State determines that such
points are more representative of treated (disinfected) water quality within the distribution system.
Heterotrophic bacteria, measured as heterotrophic plate count (HPC) as specified in paragraph (a)(3) of this
section, may be measured in lieu of residual disinfectant concentration.

The misleading and false information has even made it into laws which offer no protection to the public. But
that's not the state's fault either. Scientists who didn't do basic research gave the information to EPA, who
told California the guideline was law, and California made it a law. But that's not California's fault either, is it?

California's water reclaimation law claims coliform is a generic organism and the wastewater treatment plant
coliform reports must maintain consistency with the montoring data on EPA's existing data sets.

Under California's Title 22, Total coliform (some disease organism anyway) should average 2.2 MPN/100ml
(most probable number)/mililiter (gram)) over a 7 day period. However, for one day the coliform could be
240 MPN/100 ml. Translated, that means the most probable number would be 2,400 pathogenic bacteria
per liter of reclaimed water for a full day that is used in Salinas County to irrigated spinach and lettuce.  
Could millions of liters of water with 2,400 pathogenic bacteria in each one used to irrigate crops during a 24
hour period contaminate the lettuce and spinach that you eat raw?

Coliforms are inactivated at low levels of disinfection. Many bacteria and viruses are only inactivated at
medium to high level desinfection in a sterile laboratory situation. Inactivate simply means the bacteria and
viruse may be viable, but nonculturable by standard methods.

There have been nine contaminated food outbreaks traced back to Salinas valley since 1995. Only bagged
and tagged processed lettuce and spinach could be traced. The last two outbreaks have been a 100 million
dollar disaster for California farmers using reclaimed water.  Since bacterial and virus biofilms build up in
water distrubtuion pipes and they break loose from time to time, if this were the case, there is the potential
that it will probably get much worse for the farm industry as bacterial biofilms build up in the irrigation pipes
and break loose. Beside of course, those 2,400 cfu of some pathogenic bacteria that is allowed to be
released in each liter of reclaimed water.

CALIFORNIA  TITLE 22  Section 64655(b)

Total coliforms serve as a generic indicator organism that captures a broad range of potential
bacteriological contamination.  Fecal coliform and E. coli are indicators of specific fecal or human waste
contamination.  Coliform monitoring has been used by the industry for many years and the Information
Collection Rule (61 Fed. Reg. 24354 (May 14, 1996)) database is populated with coliform monitoring data.  
This regulation specifies coliform monitoring to maintain consistency with existing data sets.


6.        Tertiary Recycled Water  Tertiary recycled water shall be coagulated (except as identified in Part C
below), and filtered, and meet the following total coliform, disinfection process and turbidity limits prior to
delivery for reuse purposes: .

a.        Total coliform          After adequate contact with disinfectant the number of total coliform organisms
shall not exceed: (1) a median value of 2.2 MPN/100ml as determined from the bacteriological results of the
last seven days for which  sample analyses have been completed, and (2) a maximum value of
23MPN/100ml in more than one sample in any 30 day period. No sample shall exceed a total colform value
of 240 MPN/100 ml.

That is an oxmoron requirement. You can not exceed 2,2 mpn, with a maxium value of 23 mpn, but don't
exceed 240 mpn one time a month??

The California Counties are even more confused concerning the colifom situation in swimming

California State Standards for swimming water
Total Coliform: 1,000 per 100 ml if Fecal/Total is >.1;  

10,000 per 100 ml if Fecal/Total is <.1                         

Fecal Coliform: 400 per 100 ml                                     

Enteroccoccus: 104 per 100 ml                                   

Santa Cruz County seems to be very confused about the coliform testing.
Test results reflected below are the latest analysis of the locations indicated. NA indicates "not available at
this time." TNTC indicates levels "too numerous to count". Safe swimming standards indicate that single-
sample levels of enterococcus bacteria greater than 104 cfu's, E. coli or fecal coliform bacteria greater than
400 cfu's, and total coliform levels greater than 10,000 cfu's per 100mls. of water may contain disease-
causing organisms and be hazardous to swimmers.  [They kidding, aren't they?]

El dorado County, California seems to have an even more confusing understanding of coliform
test for water.

El Dorado, County, California ENVIRONMENTAL HEALTH

Coliform Bacteria Contamination - Frequently Asked Questions

What are coliform?

Coliform bacteria are indicator organisms which are used in water microbiological analysis.
Coliforms are a
group of bacteria which are readily found in soil, decaying vegetation, animal feces, and raw
surface water.
They are not normally present in deep groundwater and treated surface water. These
indicator organisms may be accompanied by pathogens (i.e., disease-causing organisms),
but do not
normally cause disease in healthy individuals.
However, individuals with compromised immune systems
should be considered at risk.  
Coliforms, rather than the actual pathogens, are used to assess water
quality because their detection is more reliable. Pathogens appear in smaller numbers than
coliforms, so are less likely to be isolated.
 Drinking water found to contain coliforms is considered
biologically contaminated.

How does the laboratory detect coliforms in a water sample?

Since visual examination of water under the microscope is unreliable, the County Laboratory uses
the Colilert presence/absence method. In brief, this method combines two separate examinations. First, the
100 milliliter sample is combined with growth medium, and then incubated for 24 hours at 35.0 degrees
Centigrade. After 24 hours, only coliform bacteria will use the growth medium for food,
resulting in a
change in the water sample's appearance.
At the same time, a second examination is performed to
determine if the coliform present is from feces. Thus, the test is completed 24 hours after it has begun.

A TOTAL COLIFORM ABSENT report means that there are no coliform bacteria present at the time of
sampling and the water may be considered bacteriologically safe to drink.

A TOTAL COLIFORM PRESENT report means that coliform bacteria is present at the time of sampling and
the water may not be considered safe to drink. You will be advised to super-chlorinate the water system.

A FECAL COLIFORM (E.COLI) PRESENT report means that fecal coliform bacteria is present at the time of
sampling and the water may not be considered safe to drink. You will be advised to super-chlorinate and/or
make modifications to the water system.

The California Department of Health Services sets drinking water standards and has determined that the
presence of
any coliform bacteria in drinking water is a possible health concern. A 100 milliliter
sample of water must be absent of coliform bacteria to be considered safe to drink.

With all this  misleading scientic information forming the basis for the federal rules and state law, sewage
effluent (reclaimed water) and sewage sludge have been disposed of on our food crops, lawns, parks, and
school yards for over two decades. The media started picking up on the health problems potentially
associated with the use of using sludge as a food crop fertilizer in the mid 90s. To counteract the media
attention, several states enacted food slander laws, which effectively stopped any comments about food
contamination. After all, who would dare challange the EPA's science, and its army of scientists who had
spent millions of dollars on studying sludge safety. Now, with 9 outbreaks in the past 10 years traced to the
Salinas Valley and all of the media attention, Some California representatives apparently believes they can
cover up this proble by enacting a food slander law intended to prohibit the discussion on illness and death
traced to the Salinas Valley produce.. Assembly Member Strickland apparently believes the science and law
shown above will stand up in court as proof reclaimed water could not have been the problem. Too little --
Too late.

INTRODUCED BY   Assembly Member Strickland                        FEBRUARY 22, 2007

An act to add Section 47.2 to the Civil Code, relating to


AB 698, as introduced, Strickland. Perishable agricultural product
Existing law provides for civil liability for defamation and
provides that defamation is effected by libel or slander. Under
existing law, an action for libel or slander is based, in part, on
false and unprivileged publications, as specified. Under existing
law, privileged publications are publications made in connection with
the discharge of official duties or in certain official proceedings.

This bill would allow a producer of a perishable agricultural
product, as defined, who suffers actual damages as a result of
another person's disparagement of the producer's product to recover
those actual damages if certain facts are found to be true. The bill
would define "disparagement" for these purposes as a false and
unprivileged publication regarding a perishable agricultural product
that clearly impugns the safety of the product. The bill would
require the plaintiff to bear the burden of proof as to each element
of the cause of action.
Vote: majority. Appropriation: no. Fiscal committee: no.
State-mandated local program: no.


SECTION 1.  Section 47.2 is added to the Civil Code, to read:
47.2.  (a) A producer of a perishable agricultural product who
suffers actual damages as a result of another person's disparagement
of the producer's product may recover those actual damages if each of
the following is found to be true:
(1) The disparagement clearly concerns the product specifically
produced by the plaintiff, and is not applicable to the product as it
is generally produced.
(2) The disparagement is disseminated to the public in any manner.

(3) The defendant knows the disparaging statement is false, or
acts with reckless disregard for its truth or falsity.
(4) The defendant intended the statement to cause financial harm
to the plaintiff, or either recognized or should have recognized that
it was likely to do so.
(b) The plaintiff shall bear the burden of proving each element of
the cause of action.
(c) The following definitions apply for the purposes of this
(1)  "Disparagement" means a false and unprivileged publication
made orally, in writing, or in any other visual or aural form
regarding a perishable agricultural product that clearly impugns the
safety of the product.
(2) "Perishable agricultural product" means an agricultural
product, as defined in subdivision (a) of Section 58501 of the Food
and Agricultural Code, that is sold or distributed in a form that
will perish or decay beyond marketability within a period of time.
(d) This section shall not eliminate or limit any other cause of
action that may be available.  

Now we know why the State of California changed the 1914 Public Heath Standard for coliform to the new
apparent HPC Standard which does not test for coliform, but claims to represent Total coliform. This
explains why the State of California  Counties also claims the new coliform group does does not cause
human health effects.  This also explains the proliferation of scientific garbage on the web which claim the
HPC bacteria does not cause human disease. Its evidence for the courts. The implication also, is that
Viruses, which kill more people than bacteria - and- for which there is no treatment is unimportant in the
scheme of protecting public health. That is why on, and now,,  we concentrate on EPA's PR program to spread disease contaminated reclaimed
water and bioslids on food crops and your lawns and any where else your child can be exposed. All of these
scientists who have followed EPA's
Alan Rubin (retired) down this path to disaster are trying to protect their
reputations by publishing misleading information -- but they are only digging the hole that much deeper, by
the outright lies -- according to FDA's Bad Bug Book

if E. coli is more than >1 E. coli bacteria? -- there may be
10,000 deadly coliform per liter,  plus other  deadly  
pathogenic flesh eating disease organisns that don't
respond to low levels of disinfection.

if E. coli is less than <1?  There may be 100,000 deadly
coliform per liter. Plus, see above

Other disease organisms are suppressed in the
thermotolerant E. coli test. 0157:H7 does not show up in
this test.

Now there is one deadly bacteria. It is one of the
necrotizing flesh eating bacteria.