| COLIFORM -- ENTERIC PATHOGENIC DISEASE ORGANISMS EPA -- WEF PR CAMPAIGN STILL GOING STRONG 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, SHIGELLA, EDWARDSIELLA, SALMONELLA, CITROBACTER, KLEBSIELLA, ENTEROBACTER, SERRATIA, PROTEUS, MORGANELLA, PROVIDENCIA and YERSINIA. 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. http://www.cfsan.fda.gov/~ebam/bam-4.html THE GROUP OF PATHOGENIC ENTERIC BACTERIA COMPOSING A COLIFORM OFTEN SEEN IN LAB. 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. COOPERATIVE EXTENSION UNIVERSITY OF CALIFORNIA ENVIRONMENTAL TOXICOLOGY NEWSLETTER 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] http://extoxnet.orst.edu/newsletters/n111_91.htm HPC populations greater then 500-1000 cfu/mL in drinking water can interfere with coliform/E. coli [fecal coliform] 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] http://www.dwrf.info/hpc.htm 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] http://www.wcponline.com/column.cfm?T=X&ID=2138&AT=X 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. http://www.fwr.org/waterq/frdw0003.htm 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 growth. 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. http://www.waterquality.crc.org.au/hsarch/HS26b.htm 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 Services. http://www.cfsan.fda.gov/~mow/chap17.html 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 http://deadlydeceit.com/coliforms.html 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 FOR TESTING COLIFORM ADOPTED IN 1914. 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. www.dhs.ca.gov/ps/ddwem/edt/pdfs/hpc.pdf 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. http://www.applications.dhs.ca.gov/regulations/store/regulations/R-20-01%20ISOR.doc CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD SAN FRANCISCO BAY REGION 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. www.swrcb.ca.gov/rwqcb2/download/orderno96-011.doc 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 water. 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?] http://sccounty01.co.santa-cruz.ca.us/eh/environmental_water_quality/current_water_quality_data/index.htm 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. http://www.co.el-dorado.ca.us/edc.html 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 defamation. LEGISLATIVE COUNSEL'S DIGEST AB 698, as introduced, Strickland. Perishable agricultural product defamation. 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. THE PEOPLE OF THE STATE OF CALIFORNIA DO ENACT AS FOLLOWS: 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 section: (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 www.deadlydeceit.com, and now, www.thewatchers.us, 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. |