[USCC] FW: Re: Fecal Coliform testing issues

epsteinee@comcast.net epsteinee at comcast.net
Sat Nov 4 08:09:13 CST 2006


All what you have indicated has been done as early as 1976. At USDA we conducted hundreds of studies in the field on pathogen destruction. Studies were also conducted by Rutgers U. and National Science Foundation and other institutions. Not only did we look at fecal coliforms and Salmonella, we innoculted piles with polio1 virus and parsistes to determine die off rate. We looked at regrowth. The data has been published.

Keep in mind that unless the rule is changed (Congress and USEPA) you will have to live with it. USEPA is interested only to protect public health and the environment and does not care whether you sell the product, give it away or dump it. Since the rule only applies to sewage sludge and biosolids, states do not have to use it for other feedstocks. However I highly recommend tha they do since most feed stocks contain pathogens. This includes food waste and yard waste.

Eliot

--
Eliot Epstein 
19 Preston Place 
North Easton, MA 02356 
Tel: 508-238-1631 
Cell: 781-603-7151 
E-mail: epsteinee at comcast.net

-------------- Original message -------------- 
From: frank <frank at compostlab.com> 

> U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW 
> Wyndham Orlando Resort | Orlando, FL | January 21-24, 2007 
> The National forum for those involved in the development and expansion of the 
> composting and organics recycling industry 
> CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS, 
> EXHIBITOR INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE AVAILABLE AT THE USCC 
> WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931 
> 
> 
> Hi Dan, 
> Pathogen reduction is serious business especially when we consider 
> biosolids. If we are to ever move biosolids into main stream composting, 
> as I would like to see, we need solid data that known conditions (as 
> shown in the lab using pure cultures) and procedure that will obtain the 
> conditions in the compost that are required to kill all forms of the 
> pathogens of interest. Then we need to take those conditions into the 
> field and monitored (temperatures) and verify (fecal coliform at end of 
> heat : ) ) that they have been met. More than performance based. These 
> need be solid rules. 
> 
> I agree with the "performance based" approach and "advanced monitoring 
> and reporting/information/communication systems" 
> you suggest. But this will only work if the CaDOT User, and others, is 
> given flexibility in the materials he/she is permitted to use - and this 
> is not often the case. 
> Also, to report a 'good performance' when using a certain product there 
> must be included a characterization of the product used so it can be 
> repeated. The testing required from CaDOT and most other agencies does 
> not give the necessary info to properly match the material to the 
> results IMO. And, as you mention we need weather and environment 
> conditions along with soil and plant type. And someone dedicated to 
> monitor and report how the site is doing. 
> 
> A great project, and with the right people, could make big advances in 
> using compost, and compost related products. 
> 
> Frank 
> 
> 
> Dan Noble wrote: 
> 
> >Frank and Eliot, 
> > 
> >Once again another argument for "performance based" rather than "rules 
> >based" regulations. This has been a problem with the "rules based" approach 
> >for decades... it literally "blocks" innovation that arises continuously out 
> >of new science and new technology. If we ever plan to have ever enhanced 
> >watershed environments, whose management is based on ever improving science 
> >and technology, we need to get on the journey of crafting and implementing 
> >evergreen, performance based approaches to management and regulation, it 
> >seems to me. 
> > 
> >We see it operating here in California constantly with all the CalEPA boards 
> >(air, water and waste). Seems that its time to start moving forward with 
> >new, more evergreen approaches to environmental/watershed regulations. My 
> >belief is that we now have the science and technology to head in this 
> >direction (mainly advanced monitoring and 
> >reporting/information/communication systems). 
> > 
> >Is there anyone (or group) within USCC that is addressing this, albeit much 
> >bigger, regulatory issue? 
> > 
> >Sincerely, 
> >Dan 
> > 
> >Association of Compost Producers 
> >"We Build Healthy Soil" 
> > 
> >Dan Noble 
> >Executive Director 
> >Bus: (619) 303-3694 
> >Cell: (619) 992-8389 
> >Fax: (619) 589-9905 
> >dan at resourcetrends.com 
> >www.healthysoil.org 
> > 
> >-----Original Message----- 
> >From: compost-bounces at composter.com [mailto:compost-bounces at composter.com] 
> >On Behalf Of frank 
> >Sent: Thursday, November 02, 2006 3:26 PM 
> >Cc: US Composting Council Compost Discussion List 
> >Subject: Re: [USCC] FW: Re: Fecal Coliform testing issues 
> > 
> >U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW 
> >Wyndham Orlando Resort | Orlando, FL | January 21-24, 2007 
> >The National forum for those involved in the development and expansion of 
> >the composting and organics recycling industry 
> >CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS, 
> >EXHIBITOR INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE AVAILABLE AT THE 
> >USCC WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931 
> > 
> > 
> >Eliot, 
> >Does that mean that at 55 deg c it has been shown in the lab that is 
> >enough time to kill all the pathogens and their associated more 
> >resistant stages? I am just wondering where 55 deg for three days comes 
> >from and what it is based on. 
> > 
> >It seems it is very hard to make changes to about anything because once 
> >a group has completed a task it is disbanded and there is not another 
> >with the job of keeping the regs or procedures updated as new science 
> >and experience may dictate. 
> > 
> >Thanks again 
> > 
> >Frank 
> > 
> > 
> > 
> > 
> >epsteinee at comcast.net wrote: 
> > 
> > 
> > 
> >>Frank 
> >> 
> >>E. coli is a bactrerium in the genus Escherichia and Klebsiella sp. is 
> >>in the genus Klebsiella . These are both Enterobacteriaceae. 
> >> 
> >>Facultative bacteria are able to live with or without oxygen. 
> >> 
> >>I appologize for not making the formula more clear. D is the time 
> >>depending on t which is the temperature. So if you put in55C you will 
> >>get three days. 
> >> 
> >>It is very difficult to get EPA to make a change if it is in the rule. 
> >>You may wish to contact Jim Smith at EPA. His e-mail is: 
> >>smith.james at epamail.epa.gov 
> >> 
> >>Eliot 
> >> 
> >>-- 
> >>Eliot Epstein 
> >>19 Preston Place 
> >>North Easton, MA 02356 
> >>Tel: 508-238-1631 
> >>Cell: 781-603-7151 
> >>E-mail: epsteinee at comcast.net 
> >> 
> >> 
> >> -------------- Original message -------------- 
> >> From: frank 
> >> 
> >> > U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW 
> >> > Wyndham Orlando Resort | Orlando, FL | January 21-24, 2007 
> >> > The National forum for those involved in the development and 
> >> expansion of the 
> >> > composting and organics recycling industry 
> >> > CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS, 
> >> > EXHIBITOR INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE 
> >> AVAILABLE AT THE USCC 
> >> > WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931 
> >> > 
> >> > 
> >> > Jennifer and composters, 
> >> > 
> >> > Jennifer Appel wrote: 
> >> > 
> >> > >Method A believes the following: 
> >> > > 
> >> > >Add a high nitrogen starter to the pile and heat it up to kill the 
> >> > >pathogens. 
> >> > > 
> >> > >What this ac tually does is kill both the pathogens and the 
> >> beneficial 
> >> > >species. (But this method is not looking for beneficial 
> >> organisms only the 
> >> > >removal of pathogens.) When the pile cools the bad guys come 
> >> back first. 
> >> > >(About the time you send in the sample for testing.) 
> >> > > 
> >> > >Because there was a synthetic starter used - the aerobic 
> >> bacteria that eats 
> >> > >pathogenic organisms WILL NOT start their function because the 
> >> synthetic 
> >> > >process is a chemical one and the biological process CAN NOT 
> >> START until the 
> >> > >chemical reaction has finished its process. 
> >> > > 
> >> > >One way for Method A to achieve an aerobic pathogen free 
> >> status, is to 
> >> > >inoculate the pile with the beneficial organisms after the pile 
> >> cools to a 
> >> > >temperature and aerobic status that can support your new 
> >> organisms. 
> >> > > 
> >> > >Once this has been achieved, the biology will perform the 
> >> nutrient c ycling 
> >> > >functions required to KEEP the pile aerobic and pathogen free. 
> >> > > 
> >> > > 
> >> > > 
> >> > You make a good point. With windrow composting, as I see it, the 
> >> hot 
> >> > part is killing all while at the same time the microbes in the 
> >> cooler 
> >> > band on the outside are getting established. Then we turn it all 
> >> over 
> >> > and it starts again. I don't think the pathogens (I'm not 
> >> talking about 
> >> > the indicator FC) will get established, as you suggest, because the 
> >> > aerobic conditions common in the cooler parts of the pile are 
> >> not to 
> >> > their liking. So I think this is a process of killing the spores of 
> >> > pathogens along with the vegetative phase and providing a place 
> >> where 
> >> > the benificials will take over. But your point is well taken 
> >> when in 
> >> > vessel or container composting. That kills off all and then 
> >> readies the 
> >> > material for whatever gets a foothold. Being aerobic I still see 
> >> it as 
> >> > unlikely a pathogen that normally lives in anaerobic conditions 
> >> will 
> >> > take over. FC will along with all the other common microbes 
> >> surrounding 
> >> > the pile, or on equipment that survived the process. All good 
> >> reasons to 
> >> > test after the heat phase. 
> >> > 
> >> > >Method B: (rarely used in large commercial composting operations) 
> >> > >It is also possible to NOT USE a synthetic high nitrogen 
> >> starter. This is a 
> >> > >bit more advanced. This method requires microscope time to 
> >> assess the 
> >> > >organisms in the pile, then feed stocks that promote specific 
> >> aerobic 
> >> > >organism activity to mitigate pathogenic organisms are added in 
> >> appropriate 
> >> > >proportion to promote a fully functioning aerobic compost pile 
> >> that can 
> >> > >provide 2-3 tons of Nitrogen supply if all the biology is 
> >> functioning 
> >> > >correctly. 
> >> > > 
> >> > >The SECOND reason I see for why pathogens reestablish in a pile 
> >> is becau se 
> >> > >far too many compost operations OVER WATER the pile every 3rd 
> >> day and thus 
> >> > >de-oxygenate it! Three steps forward and two steps back is a 
> >> hard way to 
> >> > >make a good product. I understand the intent of the rules, 
> >> however, most of 
> >> > >the operations I have visited could make a better product in a 
> >> shorter 
> >> > >period of time if they just used LESS WATER in conjunction with 
> >> negatively 
> >> > >aerating the piles!!! 
> >> > > 
> >> > >Moisture content and optimum temperature will vary depending on 
> >> the location 
> >> > >where the pile is made, type of feed stock, type of pathogen or 
> >> beneficial 
> >> > >organisms and the type of aeration method used... Minnesota 
> >> composting is 
> >> > >very different from South Texas composting with respect to 
> >> temperature, time 
> >> > >and moisture content - and to add to that - the type of raw 
> >> materials used 
> >> > >will require a different amount of water depending on the 
> >> biological species 
> >> > >requirement in the pile. (MSW versus food residual vs. cotton 
> >> burr, 
> >> > >in-vessel, static, etc.) 
> >> > > 
> >> > >ALL soil has 3 properties: chemical, physical and BIOLOGICAL! 
> >> The first two 
> >> > >have enough science behind them to establish good composting 
> >> practices and 
> >> > >it would appear an opportune time to add the third element 
> >> based on 
> >> > >scientific data in order to achieve a smoother process. 
> >> > > 
> >> > > 
> >> > As I see it all this should happen, and will, after the heat phase. 
> >> > Because we can -not- count on it happening in the way we want 
> >> due to so 
> >> > many variables (you point out many) and based on no 'lab prove 
> >> method' 
> >> > we should not include this in the pathogen reduction program. As 
> >> it is 
> >> > now we do include this in the program and it is giving us 
> >> misleading 
> >> > results and preventing other stabilization processes from being 
> >> used - 
> >> > like vermistabilization. 
> >> > 
> >> > Frank. 
> >> > 
> >> > 
> >> > 
> >> > > 
> >> > > 
> >> > > 
> >> > 
> >> > -- 
> >> > Frank Shields 
> >> > Soil Control Lab 
> >> > 42 Hangar way 
> >> > Watsonville, CA 95076 
> >> > (831) 724-5422 tel 
> >> > (831) 724-3188 fax 
> >> > frank at compostlab.com 
> >> > www.compostlab.com 
> >> > 
> >> > 
> >> > 
> >> > _______________________________________________ 
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> >> > 
> >> > This list is a service provided by the US Composting Council. 
> >> > 
> >> > _______________________________________________ 
> >> > 
> >> > 
> >> > Ongoing Sponsors of the USCC Discussion list are: 
> >> > 
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> >> policy e-mail alert 
> >> > service for environmental, food and agricultural industry 
> >> professionals. 
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> >> > 
> >> > Renewable Carbon Management, LLC with the containerized, 
> >> in-vessel NaturTech 
> >> > Composting System www.composter.com rcm at composter.com 
> >> > 
> >> > (c) Copyright 2006 United States - All rights reserved 
> >> > 
> >> > Members posting CC copies to the list and other addresses will 
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> >> > 
> >> > Opinions expressed represent only the poster and are not 
> >> necessarily the opinion 
> >> > or policy of any organization. 
> >> > 
> >> > Non-members of USCC are encouraged to join the Council through 
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> > 
> 
> -- 
> Frank Shields 
> Soil Control Lab 
> 42 Hangar way 
> Watsonville, CA 95076 
> (831) 724-5422 tel 
> (831) 724-3188 fax 
> frank at compostlab.com 
> www.compostlab.com 
> 
> 
> 
> _______________________________________________ 
> Compost maillist - Compost at composter.com 
> http://mailman.cloudnet.com/mailman/listinfo/compost 
> 
> This list is a service provided by the US Composting Council. 
> 
> _______________________________________________ 
> 
> 
> Ongoing Sponsors of the USCC Discussion list are: 
> 
> Food Industry Environmental Network (FIEN), a regulatory and policy e-mail alert 
> service for environmental, food and agricultural industry professionals. 
> Contact Jack Cooper 301/384-8287 JLC at fien.com --- www.fien.com 
> 
> Renewable Carbon Management, LLC with the containerized, in-vessel NaturTech 
> Composting System www.composter.com rcm at composter.com 
> 
> (c) Copyright 2006 United States - All rights reserved 
> 
> Members posting CC copies to the list and other addresses will have their 
> posting privelages suspended. No exceptions! 
> 
> Opinions expressed represent only the poster and are not necessarily the opinion 
> or policy of any organization. 
> 
> Non-members of USCC are encouraged to join the Council through our website at: 
> http://www.compostingcouncil.org/membership.cfm For discussion list policies 
> and information regarding subscribing, unsubscribing, digest or other options, 
> go to:http://mailman.cloudnet.com/mailman/listinfo/compost 
> 
> For additional help in unsubscribing or to report bugs and problems, send a 
> message to the List Manager, Jim McNelly, at compost-owner at composter.com 


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