Australian Guidelines 21 for Water Recycling

       AUSTRALIAN GUIDELINES 21 FOR RECYCLED WATER
                     DRAFT FOR PUBLIC COMMENTS REPLY

By Jim Bynum                                                                                                                        8/25/2007
Retired Safety Consultant

SEWAGE WASTEWATER REUSE: A THIRD WORLD SOLUTION TO A MODERN DISPOSAL PROBLEM
Even U.S. EPA would not attempt to regulate reclaimed water. EPA guidelines reflect states' policy.
EPA states, "Given the unknowns, limitations, and uncertainty with the current state of science and technology,
it is not possible to establish the threshold at which no observed effect would occur, just as it is not reasonable to
expect current scientific techniques to demonstrate the absence of an impact on human health."

In Australia, the proponents of sewage recycling do not want to take any responsibility for the science used to force
sewage reuse on the public and especially firefighters. They say it is safe, but don't quote them.

Health Risk Assessment of Fire Fighting from Recycled Water Mains

DISCLAIMER
This occasional paper is issued by the Water Services Association of Australia Inc. on the understanding that:
1. Water Services Association of Australia Inc. and individual contributors are not responsible for the results of any action
taken on the basis of information in this occasional paper, nor for any errors or omissions.
2. The Water Services Association of Australia Inc and individual contributors disclaim all and any liability to any person in
respect of anything, and the consequences of anything, done or omitted to be done by a person in reliance upon the whole
or any part of this occasional paper.
3. The occasional paper does not purport to be a comprehensive statement and analysis of its subjective matter, and if
further expert advice is required, the services of a competent professional should be sought.
http://www.fire.tas.gov.au/mysite/publications/pdfs/library/FireFightingFromRecycledWater.pdf

AUSTRALIAN GUIDELINES 21 FOR WATER RECYCLING:
MANAGING HEALTH AND ENVIRONMENTAL RISKS (PHASE 2)
AUGMENTATION OF DRINKING WATER SUPPLIES
DRAFT FOR PUBLIC COMMENT JULY 2007

The National Research Council that is referenced in the draft guidelines concluded in 1998 that sewage could be
considered for drinking water augmentation, " but only as a last resort and after a thorough health and safety
evaluation. Municipalities first must fully assess health impacts from likely contaminants and develop
comprehensive systems for monitoring, testing, and treatment." There is no indication in the draft guidelines that
this warning is being considered despite acknowledging the risks involved..

Draft statement:
The greatest risks to consumers of drinking water are pathogenic microorganisms; protection of water sources and
treatment are of paramount importance and must never be compromised Although a great deal of attention has been paid
to chemical quality of recycled water used to augment drinking water supplies, the risks posed by pathogens remain
significant. Impacts can be acute, severe and widespread.

Biological screening, including in-vivo and in-vitro assays, has been used to test recycled water (NRC 1998; NEWater
website6). Whole animal tests typically use mice and rats, and guideline values for many chemicals have been generated
from this type of testing. However, there are ethical issues that have to be addressed before this type of testing can be
applied, and applicability to humans can vary.

Comment:
Australia faces growing pressures on health funding because of the ageing of the population, technological changes and
increasing patient expectations. One of the technological changes appears to be that Australia followed the U.S. EPA's lead
in promoting chemical and pathogen contaminate sewage sludge as a fertilizer rather than focusing on protecting public
health. Ethical issues have not been considered since, the Draft Guidelines will continue to authorize the spreading of
pathogens in the environment which increasingly cause human soft tissue and necrotizing infections that are extremely
difficult and expensive to treat. "There is huge lack of public information about the effects of chemicals on human health
and the environment; 80-90% of all chemicals lack basic information." The Reclaimed Water Guidelines not only further
erodes protection of public health, but puts the national economy at risk based on speculation by waste industry
representatives that by some magic potion, and lack of knowledge, the pollutants (pathogens & chemicals) in reclaimed
water will not harm, or kill, enough people to be noticed.

Draft Statement:
In sewage, enteric microorganisms can be found in high concentrations. Numbers of individual
pathogens will vary, depending on rates of illness in humans and animals contributing faecal
waste. System-specific data is preferable for drinking water augmentation schemes. However, as
discussed in Phase 1 of the recycled water guidelines (NRMMC–EPHC 2006), analyses of
Australian sewage have detected 2000 Cryptosporidium, 8000 rotavirus and 7000 Campylobacter
per litre (as 95th percentiles).

Comment:
For the past 35 years wastewater disposal scientists have operated under the theory that dilution was the
solution to pollution. Unfortunately, that was a false scientific assumption based on a lack of knowledge and
engineering technology, which has caused the pollution of many rivers and the ocean. The current false
scientific theory is that if municipalities force sewage effluent reuse on the public as reclaimed water, the
resulting damage to food production, human health and the environment will not be traced back to the waste
regulators and scientific double-talk published as peer reviewed studies. As NRC noted in 1998, "Most
outbreaks of waterborne disease in the United States are caused by parasites and viruses, yet few drinking-
water systems monitor for the full range of such pathogens." So, the victims are blamed for a lack of hygiene.

A drinking water scheme using reclaimed sewage effluent is scientific quackery knowing that:
1)dilution is not a risk factor since it may only take one pathogenic organism to cause disease; 2) disinfection
does not kill all pathogenic organisms; 3) disinfection causes some pathogens to become dormant -- viable,
but non-culturable by standard test methods; 4) coliform bacteria use in drinking water testing schemes are
now pathogens; 5) Hormones and pharmaceuticals pass through the treatment systems; 6) antibiotic drug
resistant genes are transferred in a treatment plant; 7) non-pathogenic bacteria pick up virulence from dead
pathogenic bacteria: 8) deadly toxins (exotoxins, endotoxins) created when virulent bacteria are killed is
passed on through the water system, 9) Cryptosporidium, Rotavirus and Campylobacter infected protozoa are
resistant to low levels if disinfection; 10) a treatment plant failure in Milwaukee caused over 400,000 to be
infected with Cryptosporidium, over 4,000 were hospitalized and it killed somewhere between 100 and 411
people; 11) an estimated 592,000 infants and young children <5 years old die each year from rotavirus
diarrhea; 12) Campylobacter is the leading cause of enteric illness, infections, heart valves (endocarditis,
meningitis, pneumonia, miscarriage, and a severe form of Guillain-Barré syndrome, necrotizing
arteritis/periarteritis "flesh eating", antibiotic resistance: and 13) "Recycled water, even recycled or reclaimed
water that goes through years of ground purification, may contain carcinogens, mutagens and toxins for which
we don't even have tests" said, Steve Oppenheimer, Ph.D. Director CSUN Center for Cancer and
Developmental Biology

Draft statement:
In stormwater, concentrations of enteric microorganisms will be far more variable, influenced by
levels of human and animal activity in catchments, and by seasonal and rainfall patterns. Rain
events occurring after extended dry spells can lead to highly contaminated stormwater. Generally,
system-specific testing will be required to determine concentrations of pathogens present in
stormwater.

Comment:
In combination stormwater and sewage systems there is no way to control the variables of pollutants permitted
from industry and those washed into the stormwater system or prevent a by-pass when the treatment plant is
overwhelmed. Recycling enteric microorganisms through treatment plants from reclaimed water and biosolids
create stronger and more virulent drug resistant pathogens that are viable but nonculturable for short periods
of time. Just as important, where pollutants from reclaimed water and biosolids are washed onto beaches,
swimmers are put at risk.

Draft statement:
Australian and international data are available on inorganic chemicals in untreated and secondary
treated sewage. Exceedances of drinking water guideline values have occasionally been found for
maximum concentrations reported for inorganic chemicals (Table 4.4), but the 90th and 50th
percentile concentrations generally comply.

Comment:
The 90th and 50th percentile concentration still leave some people unprotected. According to a New York
City study, pretreatment by industry would not help New York City control the toxic inorganic metal pollutants.
"The 1970 to 1972 study of the sources of these heavy metals in New York City waste-water concluded that
even with zero discharge by industry, 94 percent of the zinc, 91 percent of the copper, 84 percent of the
cadmium and 80 percent of the chromium being discharged would continue to be discharged by sources
virtually immune to treatment (Ref. 1)." (Wat. Sci. Tech. (1987) Vol. 19, No. 9. p. 133)

It would appear this draft is based on old selective science which focused on a few selected examples of
disease organisms in sewage and the least damaging illness associated with the organisms. It would also
appear no one actually read the 1996 NRC report quoted. Over 1,400 disease causing organisms have
been documented.

A longer list of bacteria and the diseases they cause can be found at www.thewatchers.us
It is amazing how many of these pathogens are coliform, which they tell us do not cause disease.
Even when exposure to these pathogens is through drinking water, the infection will be blamed on
food poisoning because of a failure to have a clean kitchen or wash their hands.

Draft statement:
Source: Adapted from Feacham et al (1983), Geldreich (1990), Bitton (1999), NRC (1996)

Draft statement:
One outcome of risk assessments is to identify the level of uncertainty and specific areas where further information and
research is required to fill knowledge gaps. Proponents need to have a realistic perception of the limitations of
predictions, and convey this to stakeholders.

Comment:
Risk assessment is the tool of lazy inept government politicians with an agenda who don't have the guts to find
the answers the public needs and allow half-truths and outright lies to be published, as in this case, as scientific
facts to be used in court cases to "prove" the dead and dying are only imagining that the pathogens listed could
cause serious health problems from exposure drinking sewage. On the other hand, scientists claim the world is
over populated, so could this be a backhanded way for the government to resolve the over population problem?

An apt description of risk assessment was given by Josephine Cooper (EPA's Assistant Administrator for
External Affairs) in an article "Helping the Public Weigh Health Threats" in the EPA Journal for December, 1984 when she
said, "With microscopes, spectrographs and sophisticated calculations, scientists weave a cloth of uncertain threads. The
blanket they produce is supposed to offer the public security--security based on uncertain beliefs in uncertain risks with
uncertain solutions. (p. 11)

Just as in when U.S. EPA used risk assessment to "prove" biosolids was safe, it only implies the government should be
honest, which is followed by a public relations program intended to fool the stakeholders. As an example, U.S. EPA spent
millions of dollars on a sewage sludge biosolds pollutant risk assessment "proving" sludge used as a fertilizer was safe. It
even had the U.S. National Academy of Science (NAS) put its stamp of approval on the program in 1996. However, U.S.
EPA's 1995 Guide to the Part 503 Risk Assessment, on page 110, stated that it did not consider organic chemicals or
pathogens a part of the risk assessment. Not only that, but it did not consider the 1989 list of cancer causing organic and
heavy metal inorganic pollutants to be cancer causing in biosolids, thus, making fools out of the scientists who served on
the NAS Committee.

Draft statement:
Senior management support, commitment and ongoing involvement are essential to continual
improvement of the organisation’s activities. Senior managers should regularly review their
approach to recycled water quality management, develop action plans and commit the resources
necessary to improve operation and management.

Comment:
Senior management tend to get in a comfort zone based on the line of least resistance, the financial bottom line and politic
expedience. As an example, in 1978, senior management at U.S. EPA OW, Thomas Jorling, insisted that sludge not be
regulated under RCRA, and the Act was weakened. The watered-down Act allowed not only sludge but also industrial
wastes to be legally used as fertilizer based on state laws as is the case with reclaimed water.

Draft statement:
Drinking water augmentation schemes necessarily require a high level of performance and
management from the time of introduction. However, complacency should not be allowed to
develop, and continual improvement should always be the goal.

Comment:
Management without personal liability leads to complacency. If we can not expect a high level of performance in drinking
water management, why would we expect it in reclaimed water management, especially when management is not held
responsible for its mistakes or neglect? As an example, U.S. EPA approved tests for fecal coliform (E. coli) actually
suppress human pathogens which would cause a false positive for E. coli and don't reveal the presence of the extremely
pathogenic E. coli.

Draft statement:
Regulatory oversight and surveillance of drinking water augmentation are essential components
of effective risk management and protection of public and environmental health. Communities
provided with drinking water augmented by recycled water have the right to expect that
regulatory oversight will be rigorous and exacting. For this to occur, regulatory agencies must be
committed to providing surveillance and must have the resources and expertise to do so.
The emphasis should always be on working cooperatively; imposing penalties should be a last
resort. However, regulatory agencies should have legislative powers to enforce actions required
to protect public and environmental health. These powers should include penalties that act as
effective deterrents to non-compliance.

Comment:
In 1998 NRC recommended "Communities using reclaimed water should implement well-coordinated, public
health surveillance systems to document and provide early warning of any adverse health effects associated with
the ingestion of reclaimed water."

The sad truth is:
If the government is promoting a scheme, regulatory oversight will reflect the government position. The risk management
scheme developed by the government will prevail in court over any damage claims from the failure to protect public and
environmental health just as it has in the U.S. When the government reverses it's position from safely managing sewage
effluent and sludge to protect public health and the environment, to promoting reclaimed water and biosolids for irrigation
and as a fertilizer as close to humans a possible, any rights expected by communities are invalidated by legislative action.
Penalties are not a deterrent to compliance if the penalties, such as fines, are assessed against the people in taxes, rather
than against management.

Milwaukee is a perfect example of this regulatory quackery in the U.S., where U.S. EPA and the waste industry conspired
to deregulate sludge with high levels of chromium in it, refused to investigate health related claims, ignored a
Cryptosporidium outbreak in drinking water that effected over 400,000, put over 4,000 in the hospital and killed
somewhere between 100 and 400 people, then blamed it on animal manure, rather than the human crytosporidium strain
which doesn't infect animals as noted by CDC 4 years later. More recently, PCB contaminated sludge without enough
nitrogen to be sold as fertilizer was dumped on school grounds and playgrounds throughout the city.

Draft statement:
Validation of preventive measures (‘Will they work?’) is crucial. Schemes cannot be developed
and introduced without conclusive evidence that they will provide safe drinking water. Validation
involves evaluating available scientific and technical information (including historical data and
operational experience) and, where necessary, undertaking investigations, including performance
monitoring and water quality testing.

Comment:
It is amazing that documents such as this one lay out the problem, speak of conclusive evidence, then state conclusive
evidence is not possible, but the government is going to do it anyway, based on waste industry assurances, rather than
scientific enquiry or input from the medical community. As an example, Australia was one of the first nations to
acknowledge that treatment plant workers were subject to serious respiratory illnesses. In 1997, the Australian
government issued its "Statement of Principles concerning EXTRINSIC ALLERGIC ALVEOLITIS in the Veterans
Entitlements Act" 1986. The government recognized that working with sewage sludge was a very dangerous
occupational risk. www.rma.gov.au/SOP/97/057.pdf   Then approved sludge use as a fertilizer.

Draft statement:
Drinking water augmentation is at the leading edge of recycled water use. There is much debate
about a broad range of issues associated with water quality, potential impacts on public health,
reliability and regulation. Understanding and knowledge will never be complete and new issues
will regularly emerge. Proponents and agencies associated with schemes should be committed to
expanding their understanding of drinking water augmentation. This will require research and
development.

Comment:
Potential impacts on public health are not the concern of the waste industry, who attempt to abide by
standards and regulations adopted by the government. While it is acknowledged that understanding and knowledge will
never be complete, proponents and agencies have adopted a one sided view of science and the waste industry studies that
support their view. As an example, proponents and agencies supporting biosolids and reclaimed water use claim the
coliform group of bacteria only indicate the potential pathogen contamination. At best, they have in fact failed to keep up
with current scientific and medical research which shows that the coliform group of bacteria, as tested, are all human
pathogens. At worse, they are lying to us.

Draft statement:
Processes, technologies and other preventive measures selected need to be robust, with reliable
engineering techniques incorporated into design and operation. Preventive measures need to be
maintained and monitored to minimise variability in performance and the potential for failure.
However, it is unrealistic to expect that failure will never occur. Where failure occurs, corrective
action must be implemented immediately.

Comment:
Depending on design and operational processes, technologies and engineering techniques to minimize performance and
failures when promoting public contact with the resulting biosolids and reclaimed water is a fools game. Assuming that it
would be possible to remove all pathogens and their toxins as well as chemicals with the best management, design and
engineering technologies, and there is no studies to show that they can, a failure could be catastrophe to public health and
as in th case of Milwaukee, the catastrophe nature of the outbreak was not recognized until it had infected 400,000 people.

Draft statement:
Designers, operators and managers of schemes must have appropriate skills and training
Everyone involved in the design, management, operation and audit of recycled water systems
needs to have sufficient knowledge and skills to undertake their role. They also need to be aware
of the consequences of failure or poor performance. Responsibilities and accountabilities need to
be identified, communicated and understood.

Comment:
Knowledgeable Committees can lay out the requirements of what should happen, but this is the waste industry who's
charge is getting rid of wastewater in the cheapest manner possible with the least amount of oversight. What are the
consequences of failure or poor performance when they are attempting to follow government guidelines? For the public,
the consequences of failure or poor performance may be disease, cancer, neurological or physical problems and even
death -- for the rest someone may at best get fired after all the finger pointing.

Draft statement:
Lack of knowledge is a significant cause of waterborne disease outbreaks involving serious
illness and death. Organisations and contractors responsible for drinking water augmentation
schemes must ensure that operators have sufficient and appropriate training and qualifications to
undertake their tasks.

Comment:
If the proponents and agencies responsible for drinking water augmentation don't have the knowledge to assure the
organizations and contractors have the knowledge concerning pathogens and chemicals that put public health at risk, what
level of education, training and qualification will the operator have to undertake his task?

Draft statement:
Risk management plans are predicated on prevention and on addressing contamination as close to
the source as possible. Sewage will always contain pathogenic microorganisms. However,
chemical quality depends on inputs and can therefore be influenced by trade-waste control
programs. Questions about chemical quality have led to a great deal of public uncertainty in
relation to drinking water augmentation. Trade-waste programs are essential for preventing or
minimising contamination of source waters before treatment.

Comments:
Risk management plans are a product of government and scientific imagination. If you don't know what pathogenic
microorganisms and chemicals are in the sewage and therefor in reclaimed water, trade-waste
control programs become an inside joke of the regulators who establish limits and waste industry. As an example, U.S.
EPA established trade-waste controls on 10 inorganic chemical pollutants in it's part 403 pretreatment standards for which
it would allow removal credits for the pollutant to be discharged to the treatment plants, and those were the only pollutants
addressed in the 503 sludge biosolids policy. Not only that, but the levels of pollutants allowed in biosolids, prohibited it
from being disposed of within 75 feet of a permitted part 503 surface disposal landfill boundary. Canada adopt a similar
policy for biosolids dumped on farmland and the Walkerton outbreak resulted.

Draft statement:
Lack of regulatory oversight has contributed to outbreaks of waterborne illness from drinking
water supplies. A lack was identified as an important factor in the Walkerton outbreak in Canada,
where seven people died from drinking contaminated water (Hrudey and Hrudey 2005).
Independent regulatory surveillance and auditing should be applied to drinking water
augmentation. The public has a reasonable expectation that such schemes will be subject to
rigorous regulatory oversight. Surveillance and auditing verify that recycled water systems are
being managed and operated correctly and at a high standard, and that public health is being
protected. Outcomes should be published in publicly available reports.

Comment:
In Clark County, Nevada in 1993-94, thirty-two people died in a Cryptosporidiosis outbreak associated with municipal
drinking water, despite state-of-the-art water treatment and water quality better than that required by current federal
standards. This outbreak highlights the importance of surveillance for Cryptosporidiosis and the need for guidelines for the
prevention of waterborne-Cryptosporidium infection among HIV-infected persons.

Draft statement:
For microorganisms, the Phase 1 document describes how performance targets for can be
determined using reference pathogens, to achieve compliance with a tolerable risk of 10–6 DALYs
[disability adjusted life year] per person per year. The approach given in the Phase 1 document is equally applicable to
drinking water augmentation as covered in this document.

Comment:
Using reference pathogens to determine public risk is a fools game intended to fool the public if you have no real data of
the pathogens in reclaimed water. If the 1998 NRC recommendation is adopted, "Communities using reclaimed water
should implement well-coordinated, public health surveillance systems to document and provide early warning of any
adverse health effects associated with the ingestion of reclaimed water," citizens will hold the government accountable.

Draft statement:
All aspects — from design through commissioning to operation — need to be subject to external
oversight and auditing by a regulatory agency. This requires appropriate expertise. In some cases,
regulatory agencies may need to engage independent experts (Section 4.12). Governments have a
responsibility to ensure that these requirements are in place before drinking water augmentation is
undertaken.

Comment:
An excellent point, which the government has no intention of following. As in the U.S., the waste industry will supply the
oversight based on government policy approving reclaimed water use. A public relations campaign will be developed to
cover up the holes, and lack of oversight, and danger in the policy as outlined in the summary. More important, the draft
guidelines specifically exclude protection for the young, the old, and those with medical problems.

Draft statement:

Summary of actions
• Develop a recycled water policy, endorsed by senior managers, to be implemented within an
organisation or by participating agencies.
• Ensure that the policy is visible and is communicated, understood and implemented by employees
and contractors.
Stormwater can also contain a wide variety of biological and chemical contaminants, although
concentrations will generally be lower than those found in sewage. Industrial discharges should
be managed to minimise impacts, and stormwater should be protected from human and livestock
waste.

• average drinking water consumption is assumed to be 2 L per day for adults and 1 L per day
for children

• drinking water should be safe for use by the general population through all stages of life,
including childhood and older age; life is assumed to last for an average of 70 years

• drinking-water quality may not be sufficient for particular purposes such as renal dialysis and
other medical applications, and cleaning of contact lenses; water-quality requirements for
such purposes are outside the scope of these guidelines

• those who are severely immunocompromised may also need to take additional steps due to
greatly increased susceptibility to infection, but should do so under guidance from their
medical practitioner.

Comment:
Basically, the draft guidelines assumes that if you are in the mid-range of life, have a healthy immune system, no medical
problems and there is no system failure, the government sponsored waste industry program will not harm to many people,
providing you don't understand the scheme behind the program.

Draft statement:
4.2.4 Hazard identification and risk assessment
Summary of actions
• Define the approach to hazard identification and risk assessment.
• Identify and document hazards and hazardous events for each component of the recycled water
system.
• Estimate the level of risk for each hazardous event and each hazard.
• Determine significant risks and document priorities for risk management.
• Evaluate the major sources of uncertainty associated with each hazard and hazardous event, and
consider actions to reduce uncertainty.

Define approach to hazard identification and risk assessment
As defined in the ADWG (NHMRC–NMMRC 2004):
• a hazard is a biological, chemical, physical or radiological agent that has the potential to
cause harm
• a hazardous event is an incident or situation that can lead to the presence of hazard (what can
happen and how)
• risk is the likelihood that identified hazards will cause harm in exposed populations.

Effective risk management involves identifying all potential hazards and hazardous events, and
assessing the level of risk that they present to public health. Parameters identified as potential
risks by stakeholders, including community members, need to be carefully considered.

The method used needs to be fully understood by everyone involved in the process. Also, it needs
to be transparent not only to those directly involved but also to scrutiny by stakeholders and
external auditors. Confidence is needed that the process will identify all significant hazards and
risks.

Comment:
Hazard identification and risk assessment in this case is comparable to blind regulators and scientists gathered around an
elephant trying to describe the different components. In effect, with no data on thousands of chemicals for which no test
is available, an unknown level pathogens which will either not be tested or no test is available, and knowing their will be
plant failures, the only safety is to pray the elephant does not run wild and destroy everything in its path..

Draft statement:
Limitations
Realistic expectations for hazard identification and risk assessment are important. For example,
for any recycled water scheme, a detailed quantitative risk assessment will be possible only for a
limited range of contaminants. Hazard identification and risk assessment are predictive activities
that will often include subjective judgment and inevitably involve uncertainty. Factors that can
contribute to uncertainty include:
• lack of data
• variability in parameter concentrations, and limited data on the extent of this variability
• lack of knowledge on significance of parameters (eg questions such as ‘Do chemicals that
affect macroinvertebrates or fish affect humans?’ and ‘Are microorganisms detected in
stormwater infectious for humans?’). Variability and knowledge uncertainty are discussed in
Chapter 2 of Phase 1 of the water recycling guidelines (NRMMC–EPHC 2006).
These difficulties do not mean that risk assessment should not be performed or that it is not
useful. Complete databases and knowledge are rarely available. One outcome of risk assessments
is to identify the level of uncertainty and specific areas where further information and research is
required to fill knowledge gaps. Proponents need to have a realistic perception of the limitations
of predictions, and convey this to stakeholders.

Comment:
The following comments were written in 1998 and are still relevant today. Not only that, but at the end there is a
link to some current research that backs up the comments concerning health damages.

What many people do not realize is that government risk assessors can reach any conclusions they set out to reach. After
all they are the ones who choose the data and assumptions and make the policy decisions that go into the risk assessment.
So they can manipulate data to achieve any quantitative result they choose.

Because the general public as a whole lack the technical knowledge and do not understand fully the components of risk
assessment such as hazard identification, dose response and exposure, government risk assessors have successfully used
risk assessment to set limits or not to set limits to the benefit of the sewage treatment plants who are looking for a cheap
method of disposal of sewage sludge and effluents.

In a paper written in 1995, James Ryan of the EPA and Rufus Chaney of the USDA, describe how even flawed risk
assessments are used in making risk management decisions. According to them:

In this risk assessment process it is soon

apparent that lack of data, inappropriate data or inadequate

data on the dose-response relationship, environmental

exposure or population risk make implementation of the risk

assessment difficult and lead to generalization and or

acceptance of inadequate data. However, even with these

flaws, if done in an objective manner the risk assessment

serves as a useful analysis for risk management. (p. 6)

The 1996 NRC report Use of Reclaimed Water and Sludge in Food Production raises some disturbing questions about
EPA's use of models in human health assessment. According to NRC:

Models should, however, be used with caution. The model

itself brings no new data or information to the process,

and careful interpretation of modeling results is

required; a numerical result of a model has human health

significance only in the context of the model's

assumptions. The mathematical format and numerical

output of these models can lead to overconfidence in

their results. There is the danger that inaccurate

parameter estimates can lead to unrealistic

risk forecasts. (p. 93)

In the article "EPA's Strategy to Reduce Risk" in the EPA Journal for December of 1984, William Ruckelshaus
{former EPA Administrator} explains how in the risk management stage, they "try to balance the risk against
other social concerns, such as the benefits associated with the use of a particular chemical, and the cost of
reducing its use." (p. 2)

What is not factored into the cost-benefits is the cost of human suffering, of lowered IQs, of the loss of lives of
susceptible people--the immunocompromised individuals and children with damaged or undeveloped immune
systems who are unable to fight off the onslaught of infectious disease-causing organisms and carcinogenic
agents. diminished prospects for a fuller life, and reduced job choices.

What is not measured in the costs-benefits is the added burden to schools who must bear the cost for special
education classes for those who are retarded or borderline, and for those with learning disabilities, attention
deficits, and hyperactivity. The cost to society of the loss of its most gifted students is also not considered.
http://deadlydeceit.com/DD9.html

Pandemic diseases in the United States 1980 - 2007

Submissions on the draft guidelines are encouraged. Written submissions should be sent to:

Mr Haemish Middleton
Project Officer
NEPC Service Corporation
Telephone (08) 8419 1200
Email hmiddleton@ephc.gov.au

The closing date for submissions is Friday 21 September 2007.

Bacteria	*Draft:* Examples Illness	Comment: Example Extreme illness & death
Salmonella *Coliform*	Gastroenteritis, reactive arthritis	arterial infections or endocarditis, pneumonia or empyema, urinary tract infections, meningitis, septic arthritis and osteomyelitis, Enteric fever, rose spots) on the chest and abdomen,- intracranial, bone and joint, soft tissue, arterial, pancreatic, gallbladder and liver, kidneys (glomerulitis), the genitourinary tract infections, Necrotizing fasciitis "flesh eating", Typhoid {enteric fever), bacteremia, Pneumonia, heart valves (endocarditis), pericarditis, peritonitis, otitis media, cholecystitis, endophthalmitis, cutaneous abscesses, and infected cephalhematoma, Antibiotic Resistance
Campylobacter	Gastroenteritis, Guillain–Barré syndrome	leading cause of enteric illness, infections, heart valves (endocarditis, meningitis, pneumonia, miscarriage, and a severe form of Guillain-Barré syndrome, necrotizing arteritis/periarteritis "flesh eating", antibiotic resistance
*Pathogenic* *Escherichia coli* *Coliform*	Gastroenteritis, haemolytic uremic syndrome	Causes inflammatory diarrhea , destruction of red blood cells and kidney failure (hemolytic-uremic syndrome), urinary tract infections, bacteremia, meningitis, severe, lung infection , pneumonia, abscesses in the lining of the lungs (empyema), necrotizing "flesh eating" infections in the urinary tract and the abdominal cavity. 0157:H7 can not be treated with drugs, antibiotic-resistant.
Shigella Coliform	*Dysentery*	develop seizures, eye inflammation and reactive arthritis (Reiter's syndrome), intestinal perforation may occur, part of the rectum to be pushed out of the body, Permanent loss of bowel control can result, Necrotizing "flesh eating" enterocolitis: antimicrobial resistance
Yersinia Coliform	Gastroenteritis, septicemia	severe abscess of the lung, diarrhea, hepatic and splenic, Focal (oral) infections, bacteremia, pharyngitis, meningitis, osteomyelitis, pyomyositis, conjunctivitis, pneumonia, acute proliferative glomerulonephritis, peritonitis, and primary cutaneous, necrotlzlng "flesh eating" enterocolitis, pseudotuberculosis, acute gastroenteritis and mesenteric lymphadenitis, arthritis, septicemia, and erythema nodosum, Reiter's syndrome, black plague, Antibiotic resistance
Vibrio cholerae *Coliform*	*Cholera*	cause septic blood stream infections, necrotizing "flesh eating" wound infections, Cellulitis or ulcer formations may result, gastroenteritis, diarrhea, may lead to kidney failure, shock, coma, and death, Antibiotic resistance
Atypical Mycobacteria	Respiratory illness (hypersensitivity pneumonitis)	tuberculosis, leprosy, pulmonary disease resembling tuberculosis, lymphadenitis, skin disease, or disseminated disease, necrotizing fasciitis "flesh eating", Antibiotic Resistance
Legionella spp	*Respiratory illness* *(pneumonia, Pontiac fever)*	respiratory infections, gastrointestinal haemodialysis fistulae, pericarditis, central nervous system, wound and skin infections, Bacteraemia, severe pneumonia, Necrotizing cellulitis "flesh eating", antibiotic-resistant
Staphylococcus aureus	*Skin, eye, ear infections,* *septicaemia*	Methicillin-resistant (MSRA), cause toxic shock syndrome, scalded skin syndrome, septicaemia, genitourinary tract infections, Necrotizing fasciitis "flesh eating", destroys white blood cells, pneumonia, meningitis, boils, arthritis, and osteomyelitis (chronic bone infection). Drug resistant
Pseudomonas aeruginosa Coliform	*Skin, eye, ear infections*	colonize the lungs of cystic fibrosis patients, urinary tract infections, sepsis, pneumonia, pharyngitis, gangrene, and necrosis "flesh eating". Drug resistant.
Helicobacter pylori	Peptic ulcers, stomach cancer	leading cause of peptic ulcers and chronic gastritis in America, causes proctitis and colitis, septicemia in neonates and immunocompromised patients; gastric carcinogenesis, antibiotic resistance

Viruses	*Draft:* Example illnesses	Comment: Example Extreme Illnesses & death
Enterovirus	Gastroenteritis, respiratory illness, nervous disorders, myocarditis	enterovirus - any of a group of picornaviruses that infect the gastrointestinal tract and can spread to other areas (especially the nervous system) picornavirus - a group of single-strand RNA viruses with a protein coat poliovirus - the virus causing poliomyelitis hepatitis A virus - the virus causing hepatitis A Coxsackie virus, coxsackievirus - enterovirus causing a disease resembling poliomyelitis but without paralysis echovirus - any of a group of viruses associated with various diseases including viral meningitis and mild respiratory disorders and diarrhea in newborn infants
Adenovirus	Gastroenteritis, respiratory illness, eye infections	gastrointestinal tract, conjunctiva, central nervous system, and urinary tract; many species induce malignancy, human Obesity
Rotavirus	Gastroenteritis	Gastroenteritis, infant diarrhea, -- 592,000 infants and young children <5 years old die each year from rotavirus diarrhea,
Norovirus	Gastroenteritis	see Calicivirus
Hepatitis A	Infectious hepatitis	See entrovirus
Calicivirus	Gastroenteritis	---(Noroviruses - Norwalk - Norwalk like viruses) acute gastroenteritis and inflammation of the stomach and intestines Human noroviruses are the predominant cause of foodborne gastroenteritis worldwide. (August 2007) Human type norovirus found in cattle.
Astrovirus	Gastroenteritis	Astroviruses that infect humans have been poorly studied due to the fact that they do not grow in culture.
Coronavirus	Gastroenteritis	SARS, upper respiratory, gastrointestinal tract, pneumonia, new viruses discovered.

Protozoa	*Draft*: Example of illness	Comment: Extreme illness & death
Cryptosporidium	Gastroenteritis	respiratory problems, cholecystitis, hepatitis, and pancreatitis
Giardia	Gastroenteritis	Children who have a severe giardia infection may fail to grow normally or have learning difficulties later in life.
Entamoeba histolytica	Amoebic dysentery	Amebiasis causes colitis, ,ameboma, fulminant colitis, and rectovaginal fistulas. necrotizing colitis, dysentery and liver abscess, intraperitoneal rupture , Pleuropulmonary amebiasis, Cerebral amebiasis and kills an estimated 100,000 people every year, according to the World Health Association.
Helminths
Taenia (T. saginata)	Tapeworm (beef measles)	Seizures, hydrocephalus, blindness, strokes, meningitis, encephalitis, irreversible brain damage, myositis, and myocarditis may occur. Death may subsequently occur
Ascaris	Roundworm	dyspnea, hemoptysis, eosinophilic pneumonitis - Loeffler’s syndrome), airway obstruction, lacrimal drainage obstruction, acute interstitial nephritis, and encephalopathy, partial or complete bowel obstruction in large numbers, or they can migrate into the appendix, hepatobiliary system, or pancreatic ducts
Trichuris	Whipworm	Muscle and other tissue invasion, severe chronic diarrhea, (chronic trichuris colitis with growth retardation), or rectal prolapse, appendicitis, allergic manifestations such as urticaria, rhinitis and eosinophilia

A longer list of pathogenic Viruses can be found at www.thewatc hers.us

More information on Protozoa and Helminths