[USCC] Setting Industry Standards

Thu Nov 9 16:42:02 CST 2006

Frank and discussion group,
Frank, your point is well taken, but the problem does not affect 99% of
the US farmland (a few that use composted animal wastes) that is not
growing lettuce and spinach adjacent to cow pastures that may be
leaching unwanted pathogenic microorganisms to surroundings. This
appears to be an isolated incident and California is an accidental
participant in the media paranoia over what were apparently accidental
releases of pathogens from external sources unrelated to the composting
industry.  Why spread the paranoia to include the composting industry
when there has been no evidence to suggest a problem exists?  Those
fields weren't even organically grown.  I think that we would be doing
the industry a disservice by bringing the paranoia to this discussion
group.  This has little to do with being an industry leader, but it does
play into the hands of those who would like nothing better than to see
all biosolids and manures banned from land application; composted or
not.  There are other crops that can be grown on those same fields that
are not as liable to be contaminated by potential pathogenic bacterial
sources that would affect human health.

I think that the incident is being blow out of proportions to the point
where an advocate for the use of sewage sludge in composting would
become entranced by the thought of an organic source of contamination
causing problems for an entire farming industry.  If you want to test
for this pathogen in composted manures, you may be unhappily surprised
at what you find, or you may not find a problem at all.  And, what
happens if you do find a few of these organisms per gram of compost;
what level is acceptable?  The US EPA 503 regulations say that 1000
CFU/gram is acceptable for unlimited application of fecal coliform
contaminated materials to soils (and E. coli strains are the indicator
for most of these tests).  If you think these industry standards used to
the present date are insufficient, and there has been no evidence of
this, by all means, your laboratory can take the lead in assessing the
risk, but lets not make something out of nothing at this time.  (GO FOR
IT FRANK!!!)

Dave Schellinger  

-----Original Message-----
From: compost-bounces at composter.com
[mailto:compost-bounces at composter.com] On Behalf Of frank
Sent: Thursday, November 09, 2006 11:48 AM
To: US Composting Council Compost Discussion List
Subject: Re: [USCC] Setting Industry Standards

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David, and composters

>
> Frank,
>What happens if much of the composted manure is found to contain the 
>pathogenic strain of E. coli?
>
Good question. We, all in USCC,  will need to do something to find a
means to minimize the risk. Perhaps test for E Coli 0157 at point of
sale.

>Will that compost producer be placed at risk because some persons are 
>overly cautious and allowed the incidence of a non-compost related 
>contamination event to influence the pathogen testing regime for all 
>composted manures?
>
Yes - that composter will and should be placed at risk until the problem
is solved to not place all composters at risk. We should not wait until
someone else discovers their problem. "Overly cautious" !! Living in the
area surrounded with lettuce and spinach fields being plowed up because
of no sales, I suggest this is not being overly cautious. Finding E Coli
0157 in a lot of compost samples will make the clopyralid problem seem
like someone found a dirty diaper in a compost pile. All I am suggesting
is the USCC fund a Fact Finding mission to show that we are not affraid
to look into potential problems and able to police our own to protect
the public. Once the fact finding mission completes we stop the program
(hopefully) or make the needed changes in composting procedure and
monitoring to ensure the public is safe. Isn't this the purpose of the
USCC???

>  There is no current reason to
>stress about the pathogenic strain of E. coli in composted manure 
>because the current fecal coliform testing program the uses EC-MUG 
>media tests for the presence of E. coli as the indicator species for 
>fecal coliform bacteria, which is a test for pathogen concentrations.
>
We use the MPN 555 procedure. The E coli test that shows coliform at a
high, but less than 1000 per gram still passes. It would be nice to know
if it is the E Coli 0157 strain that is at 1000 per gram we are looking
at. I suggest another, more specific procedure that goes to less than
one per 25 grams for the 0157.

> My
>opinion is that labs could add the pathogen test to their list, but it 
>shouldn't necessarily be included as an STA test and would really only 
>add to the fear factor related to compost use.
>
I agree. We only add it if we find it necessary during the fact finding.

But more important we (USCC) have a system set up that will quickly take
control of these types of problems.  IMO we are so close, having all the
systems in place, but they are left incomplete and are not being used as
intended. Testing for E Coli 0157 is an opturinity to show regulators,
and us, that it works. And that we are not afraid of what we will find
and can handle problems as we find them.

>Whether the pathogenic
>strain is present or not, the 503 regulations should still be used as a

>guideline for testing pathogens. If there are greater than 1000 CFU/g 
>fecal coliform bacteria (E. coli), there is a problem.  If not, the 
>risk is low.
>
>  
>
I would like to see us (USCC) move away from the EPA 503 and develop our
own limits, (lower than EPA 503) based on our findings. But that is
another subject. I think 1000 per gram of E Coli 0157 is a little high
when looking at all the problems we have seen. Before setting a
standard, or waiting for someone else to do it for us, we should find
our what is out there. Fact Finding

Frank

>Dave Schellinger
>W. A. Callegari Environmental Center
>
>  
>

--
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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