| FECAL COLIFORM QUESTION -- MARK MECKES EPA Virologist -- Microbiologist Fecal coliform is E. coli For the past 25 years EPA has claimed sludge was safe to use as a fertilizer, if it only contained low levels of fecal coliform. In 1993, EPA claim that safe low level of fecal coliform was 1,000 most probable number (MPN) bacteria per gram for Class A and 2,000,000 MPN per gram for Class B. If the sludge met these numbers it was biosolids. According to EPA, these fecal coliform are not disease causing organisms, but instead indicate that disease causing organisms may be present. EPA has never defined a fecal coliform. It would appear that no sludge scientist has ever ask, or knows, what a coliform is. When ask the question, Dr. Meckes identified the 48 hour test method used to identify the deadly gram negative family Enterobacteriaceae, then suggested coliform did not cause diseases. However, when ask to specifically identify fecal coliform he acknowledge the 24 hour test was primarily to identify one member of the deadly family Enterobacteriaceae, E. coli. Without considering the multi-drug resistant injured viable, but nonculturable gram negative bacteria coming out of the treatment plant, we have to reconsider the safety of biosolids and part 503 which allows 1,000 mpn of E. coli 0157:H7 in Class A sludge and 2,000,000 mpn of E. coli 0157:H7 in Class B sludge. -------------------------------------------------------------------------------------------------- Subject: Re: Rubin's suggestion Date: 7/16/2007 2:46:07 P.M. Pacific Daylight Time From: BynJam Reply To: To: Meckes.Mark@epamail.epa.gov CC: rubinhial@cox.net, FPecar4525, edo_mcgowan@hotmail.com, hshields@worldpath.net, cgsnyder@post.harvard.edu, maureen.reilly@sympatico.ca, Cwwms3@wmconnect.com, Fg325, FDaly1880, Wwanglia, stevens.rick@epa.gov Dr. Meckes. Yours was the first study (1982) I could find to showed drug resistant bacteria was coming out of treatment plants. That was a very important study EPA has ignored and it has gotten much worse. Now, I do believe Alan Rubin set you up as the fall guy for the whole sludge and reclaimed water debacle. It may be EPA's position that coliform don't cause diseases, but the medical literature shows that fecal coliform as well as coliform bacteria (family Enterobacteriaceae) are now serious disease causing organisms. People are going to be rather pissed when they find out EPA has lied to them about the danger of exposure to these coliform. A partial list is below. In a message dated 7/16/2007 10:44:11 A.M. Pacific Daylight Time, Meckes.Mark@epamail.epa.gov writes: The total coliform group consists of several genera of bacteria belonging to the family Enterobacteriaceae Fecal indicator bacteria are used to assess the microbiological quality of water because although not typically disease causing, they may be found in relatively high densities following a pollution event and they have been (but are not always) detected in concert with some waterborne disease-causing (pathogenic) organisms. In a message dated 7/16/2007 12:53:54 P.M. Pacific Daylight Time, Meckes.Mark@epamail.epa.gov writes: For example, most strains of Escherichia coli will ferment lactose under the elevated temperature test for fecal coliform and therefore will meet the definition of "fecal coliform." Similarly, some strains of Klebsiella will also ferment lactose under these same test conditions and will meet the definition of "fecal coliform". Fecal Coliform 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. In 1997, 1562 bacterial isolates were recovered from hospitalized patients with skin and soft tissue infections (SSTIs) in 30 United States (U.S.) and 8 Canadian medical centers between October and December, 1997. The overall rank order of recovery of the six most common pathogens was Staphylococcus aureus (42.6%) > Pseudomonas aeruginosa (11.3%) > Enterococcus spp. (8.1%) > Escherichia coli (7.2%) > Enterobacter spp. (5.2%) > beta-hemolytic streptocci (5.1%). Coliforms -- Gram- negative rods are usually associated with intestinal infections which may spread to other parts of the body. The term EPA uses for these infections is gasteroenteritis. 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. 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. Jim Bynum ----------------------------------------------------------------------------------------------------------- Subject: Re: Rubin's suggestion Date: 7/16/2007 12:53:54 P.M. Pacific Daylight Time From: Meckes.Mark@epamail.epa.gov Reply To: To: BynJam@aol.com Mr. Bynam: Most likely this confusion is due to the fact that total and fecal coliform are defined by the methods used not the tenets of systematic bacteriology as I mentioned in my previous e-mail. Since the methods used define the organism as a "total" or "fecal" coliform then variants from a number of genera may meet the growth criteria and therefore be designated as a coliform. For example, most strains of Escherichia coli will ferment lactose under the elevated temperature test for fecal coliform and therefore will meet the definition of "fecal coliform." Similarly, some strains of Klebsiella will also ferment lactose under these same test conditions and will meet the definition of "fecal coliform". Thermotolerant strains/variants of virtually any of the Enterobacteriaceae would also be defined as "fecal coliform" as long as they produced acid and gas under the specified test conditions. Mark C. Meckes U.S. EPA (MS-387) 26 W. Martin Luther King Drive Cincinnati, OH 45268 ----------------------------------------------------------------------------------------------------------- Subject: Re: Rubin's suggestion Date: 7/16/2007 11:10:25 A.M. Pacific Daylight Time From: BynJam Reply To: To: Meckes.Mark@epamail.epa.gov In a message dated 7/16/2007 10:44:11 A.M. Pacific Daylight Time, Meckes.Mark@epamail.epa.gov writes: The fecal coliform group is a subset of the total coliform and it is also defined by the method used for detection. These are facultative anaerobic, gram-negative, non-spore-forming, rod-shaped bacteria that ferment lactose (specifically EC medium) with gas and acid formation within 24 h at 44.5 degrees C. Dr. Meckes, I want to thank you for your timely response. Could you elaborate on the genera of bacteria in this subset of coliform? That seems to be the biggest point of confusion. Thanks Jim Bynum ----------------------------------------------------------------------------------------------------------- Subject: Re: Rubin's suggestion Date: 7/16/2007 10:44:11 A.M. Pacific Daylight Time From: Meckes.Mark@epamail.epa.gov Reply To: To: BynJam@aol.com Dear Mr. Bynum Fecal indicator bacteria are used to assess the microbiological quality of water because although not typically disease causing, they may be found in relatively high densities following a pollution event and they have been (but are not always) detected in concert with some waterborne disease-causing (pathogenic) organisms. Additionally, indicator organisms are often more robust than pathogenic microorganisms surviving treatments designed to disinfect water and waste streams when pathogenic strains are not detectable. Assays for indicator organisms are usually simple, fast and inexpensive compared to test protocols used for the analysis of specific pathogens which often are complex, slow, and expensive. The total and fecal coliform groups are commonly used as indicators of fecal pollution. The total coliform group consists of several genera of bacteria belonging to the family Enterobacteriaceae. The historical definition of this group has been based on the method used for detection (lactose fermentation) rather than on the tenets of systematic bacteriology. Accordingly, when the fermentation technique is used, this group is defined as all facultative anaerobic, gram-negative, non-spore-forming, rod-shaped bacteria that ferment lactose with gas and acid formation within 48 h at 35 degrees C. The fecal coliform group also consists of several genera of bacteria belonging to the family Enterobacteriaceae. The fecal coliform group is a subset of the total coliform and it is also defined by the method used for detection. These are facultative anaerobic, gram-negative, non-spore-forming, rod-shaped bacteria that ferment lactose (specifically EC medium) with gas and acid formation within 24 h at 44.5 degrees C. You state: "There seems to be a lot of confusion within EPA, USDA, FDA, CDC and other scientists as to the nature of these indicator organisms." I would surmise that any apparent "confusion" is due in part to how a particular agency defines "indicator organisms", and how that definition is applied to specific data obtained in response to data calls, regulatory requirements and research studies. As noted above, the presence of an indicator organism in a given sample provides some evidence of a possible pollution event or contamination, but it does not necessarily mean that pathogens are present. Mark C. Meckes U.S. EPA (MS-387) 26 W. Martin Luther King Drive Cincinnati, OH 45268 ----------------------------------------------------------------------------------------------------------- Subject: Rubin's suggestion Date: 7/14/2007 10:54:30 A.M. Pacific Daylight Time From: BynJam Reply To: To: MECKES.MARK@EPA.GOV Dr. Meckes Recently, I questioned Dr. Rubin about the nature of fecal coliforms as, "There seems to be a lot of confusion within EPA, USDA, FDA, CDC and other scientists as to the nature of these indicator organisms. I was wondering if you would be willing to share your knowledge of the organisms that make up fecal coliform. People want to resolve this question once and for all." Rubin replied, "The people to direct your questions to are Drs. Jim Smith and Mark Meckes at EPA's ORD laboratory in Cincinnati, Ohio. They are actively involved in microbial issues re biosolids and wastewaters as well as ambient waters." I would appreciate it if you could answer the question. Thanks and best regards. Jim Bynum |