[USCC] Fecal Coliform testing issues

[epsteinee@comcast.net]

If a sample had fecal coliform (FC) bacteria when shipped, there could be regrowth. When New York City sent their biosolids to Texas and Colorado they found that before shippment they met the USEPA fecal coliform count of less than 2 million as required cor Class B. When the material arrived in the west the count was higher and did not met the regulations.

USEPA's regulations 40CFR503 state that the release of a product is based on testing before shipment. Therefore one should test the product before shipment and avoid a second remote test. The test should be reported as MPN. The membrane filter method is not allowed.One needs to understand the rational for the 1000 FC regulatory requirement. In 1988 Yanko for LA County Sanitation Districts conducted a study for USEPA. He found that when the FC count was below 1000 MPN per gram total dry solids no Salmonella sp. were detected (details in Epstein, 1997 "The Science of Composting" pg. 459). Appendix F of the regulations provides for sample preparation for fecal coliform and Salmonella sp. bacteria. 

I have always advised my clients to test for Salmonella sp. bacteria rather than fecal coliform.

Eliot Epstein
Epstein Environmental Consultants, LLC

--
Eliot Epstein PhD 
Adjunct Professor of Public Health
Boston University
19 Preston Place 
North Easton, MA 02356 
Tel: 508-238-1631 
Cell: 781-603-7151 
E-mail: epsteinee at comcast.net

-------------- Original message -------------- 
From: ALFRED RATTIE <arconsulting1 at verizon.net> 

> U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW 
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> WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931 
> 
> 
> Some participants of the USCC's STA Program are experiencing a failure to meet 
> pathogen reduction (fecal coliform) standards as required by EPA 503 
> regulations. This, while not a seemingly unusual situation; 
> - does not always occur with a given producer's compost 
> - sometimes occurs only after shipping to a distant STA lab, but not during 
> local lab testing (some producers test twice) 
> - is occurring with both yard trimming and biosolids compost 
> Two examples of recent problems are listed below: 
> ******************************************************************************** 
> ************************************************************************* 
> 1) I had a series of conversation with an STA lab and several others regarding 
> the fecal regrowth issues. Case in point, a recent analysis showing a fecal 
> count of 1,900 was received. The five windrows that were composited and sampled 
> for this test each passed local lab PFRP testing, i.e. fecal coliform analysis. 
> I have documented proof of this. Now we have a set of lab results that reflects 
> data that makes this a class 2 product rather than a class 1 product that it 
> started out as when it came out of the PFRP process. Again, we have records 
> documenting time and temperature data as well as the local lab fecal colifrom 
> results. What would account for this? 
> 
> 2) I was failing fecal coliform testing when I shipped my compost to an STA lab 
> using the prescribed TMECC practices. This ended when I used a courier service 
> to make an immediate delivery. Is there a regrowth issue associated with 
> shipping and handling? 
> ******************************************************************************** 
> ************************************************************************* 
> The USCC's STA Program requires participants to pass both pathogen and metals 
> testing. We are struggling to understand why these compost producers are 
> experiencing this problem. All input is welcome. 
> 
> Thanks, 
> Al Rattie 
> USCC STA Program Administrative/Technical Manager 
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