[USCC] FW: Re: Fecal Coliform testing issues

[Tim Evans]

I hope the following helps in this discussion.  You still need a good FC
methodology (including the whole sampling to lab chain) but ... 

In the UK we have adopted HACCP (Hazard Analysis Critical Control Point) as
the basis for treating organic residuals including biosolids [but not manure
on farms].  Just one comment, if Walkerton had not convinced people, the
recent O157:H7 spinach should have made people realise that the pathogen
risk to humans from manure is much greater than from biosolids.  However,
back to HACCP: it is a paradigm shift in that although you need output
standards for the product from the process, you don't use end-of-pipe
testing as the means of assuring compliance.  [Hazard Analysis and Critical
Control Point (HACCP) for Composters.  ISBN 0-9532546-6-6 The Composting
Association, Wellingborough, England]

Until the early 1960s food quality was controlled by end-of-pipe testing.
NASA questioned the wisdom of this for the manned space program - they did
not want to risk food poisoning of astronauts when they are in space.  NASA
realised that they knew the quality of the food they had [destructively]
tested but not the food that was going into space so they asked the
Pillsbury company to come up with something better, their answer was HACCP,
which has become the international system for safety of food, it is
maintained by FAO.  When those who treat organic residuals use HACCP they
are talking the same language as those who buy produce from farms, which is
a considerable advantage. 

Basically, you look at what you are intending to produce and the hazards
whose risks you want to control in the product(s).  Then at each step of the
process, does it control the risk of one or more of those hazards and if so
is there a possibility of by-pass or recontamination further down the
process, if the answers to those questions are yes, no and no respectively,
the process step is a critical control point (CCP) for that hazard.  The
operating conditions for the CCP are set so that they control the risk of
the hazard to whatever level is decided to be acceptable, the threshold
conditions are called the Critical Limits (CL).  If the CCP always operates
within its CLs then everything that goes through the CCP will have its risk
controlled and by recording the operating conditions (preferably
continuously) you have a record of control.  HACCP also requires you
pre-plan corrective action for those times when conditions go outside the
CLs.  Initially the process is 'validated' by end of pipe testing to
determine that the CLs are correct, there's no by-pass, etc. and then the
frequency of end-of-pipe testing is reduced because it is then
'verification' that the CCPs and CLs are working - the primary proof of
control has become the [continuous] record of the operating conditions.

Some people in industries with a history of regulation find this difficult
to get their heads around because they are used to being told by their
regulators what to do; they want to be told what to do and then to do it at
minimum cost (CATNAP).  They initially find HACCP a bit scary because
essentially it says 'you are grown up, nobody is going to tell you how to do
it, you work out a process, prove it works and then monitor its operation'.
However, when they have the 'light-bulb moment' they realise the strength of
HACCP and that it is a better paradigm. 

regards

Tim

Dr Tim Evans
TIM EVANS ENVIRONMENT
Stonecroft, Park Lane, Ashtead, Surrey KT21 1EU England
tel/fax +44 (0) 1372 272 172 mobile +44 (0) 7816 833 991
tim at timevansenvironment.com



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