[USCC] Fecal Coliform testing issues
frank
frank at compostlab.com
Wed Oct 25 18:23:25 CDT 2006
Eliot,
I realize what the regs say they -must- do but that doesn't make them
right. And no one tests for pathogens when the compost leaves the gate.
Only fecal coliform is tested as an indicator that ....l o n g .....
before the compost was hot.
Making someone test for parasite ova and enteric viruses at point of
sale seems pointless when you consider the problem of getting a
representative sample together with detecting in the range required for
safe handling on such a complex matrix as compost. And there are so many
more possible pathogens. Nothing more than punishing the composter.
I suggest the only way is to make sure the temp is high enough for the
time required followed with confirmation with a fecal colif. at the end
of the heat cycle. I realize the problem with regrowth of fecal coliform
during curing and, therefore, potential regrowth of the pathogens as
well. Testing F Coli at the very end will not give us the info we need -
that is if spores and more resistant forms of pathogens have survived.
We need to use all our tools to make sure the heat cycle is done
properly because there is no way to test for the many, many specific
pathogens. Moving the fecal test to the end of heat is making better use
of that tool. Another is better heat monitoring (temperature) and
planned rotating windrows to prevent the chance of improper mixing of
windrows. Then before sale make sure the compost is stabilized using the
TMECC BAC test. That may be after vermistabilization or conventional
'time' stabilized but, however it is stabilized, it should be considered
having gone through EPA pathogen reduction requirements. Even if the
requirements need to be changed!!
.
Frank
epsteinee at comcast.net wrote:
> Frank,
>
> You may differ as to when to test for E-coli or Salmonella. However if
> one is composting biosolids they must determine the pathogens when the
> product leaves the gate. If this is not done then they violate the
> Federal regulations as stated in 40CFR503. The specific wording pg. 32
> of EPA/625/R-92/013 are: measurement of fecal coliforms or Salmonella
> ..."at the time the sewage sludge is used or disposed, at the time
> sewage sludge is prepared for sale or give away in a bag or other
> container for land application or at the time the sewage sludge or
> material derived from the sewage sludge is prepared to meet the
> requirements in 503.10(b), 503.10(c), 503.10(e), or 503.10(f)." This
> is part of alternative 5.
>
> I had one coustomer who did not meet these regulations. Region 5
> prevented the removal of the product from the site until parasite ova
> and enteric viruses as well as bacteria were done. This was very
> expensive.
>
> 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
> >
> >
> > Eliot, Dave and composters
> >
> > I agree the compost needs be stabilized 'by some means' to
> prevent the
> > coliform and other facultative anaerobic from getting
> re-established.
> > Like the E. Coli 157 found in our back yard on the spenich fields I
> & gt; guess that could even manage to repopulate in an unstable
> 'compost'. We
> > are planning to do tests for the E Coli 157 on several samples a
> week to
> > get an idea of how much of an unknown problem it is. Then when
> we are
> > asked we can say we tested and found none (hopefully).
> >
> > But we differ in that I think the fecal coliform test should be
> done
> > after the heat stage. We have other and better means to
> determine if the
> > compost is stabilized like the BAC test.
> >
> > Frank
> >
> >
> >
> > epsteinee at comcast.net wrote:
> >
> > > Frank,
> > >
> > > 1. Regarding sampling and shipping I suggest that composters
> follow
> > > the USEPA 40CFR503 Appendix F in the Document Control of
> Pathogens and
> > > Vector Attraction in Sewage Sludge. The latest document
> > > EPA/625/R-92/013 was issued on July 2003.
> > >
> > > 2. Since in the docume nt a give-away sample should be tested
> before it
> > > leaves the gate, I absolutly recommend that only a cured
> sample be
> > > tested and that the end of curing be based on a stability test of
> > > either carbon dioxide evolution or oxygen uptake.
> > >
> > > 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 an d 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
> > > >
> > > >
> > > > Al, composters,
> > > >
> > > > There are two reasons for this as I see it.
> > > > 1) We take the temperature of every compost sample when we
> > > receive it
> > > > and many come in at room temperature. I suggest we look at the
> > > > packaging. I suggest a small compact, w ell insulated package
> > > containing
> > > > two one gallon plastic bags of compost with plenty of 'blue'
> > > frozen ice
> > > > packs. Also, I suggest making sure the compost is refrigerated
> > > before
> > > > the compost is pla ced into the container because I think a lot
> > > of warm
> > > > compost is placed into the container and the ice is long
> used up
> > > just
> > > > bringing the temperature from warm to cold.
> > > >
> > > > 2) When in an active compost pile the bacteria is in decline
> due to
> > > > temperature and not due to lack of carbon. When
> time-temperature
> > > has
> > > > been met the compost is moved to curing and the temperature
> > > moves in the
> > > > direction to a more favorable condition and the microbes become
> > > more
> > > > active. We should expect an increase. Only if the compost is
> > > very stable
> > > > (no available carbon) or dried out will the count stay low. The
> > > question
> > > > for me is should we test the compost directly after time-temp
> > > and before
> > > > curing? We a re counting on all the real pathogens to be
> killed off
> > > > during this heat process so can we assume its only the
> indicator
> > > > microbes that regrow? I think this is a valid assumption
> because we
> > > > permit up to 1000 indicator microbes per gram to live and still
> > > call it
> > > > safe. Allowing them to live we can only expect them to increase
> > > during
> > > > curing and, perhaps increase to above the 1000 limit. As I have
> > > > mentioned before I think we should put more importance on
> > > measuring heat
> > > > and suggest the fecal test be samples directly after
> temp-time and
> > > > before curing as an indicator the heat has been met through out
> > > the pile.
> > > >
> > > > Frank
> > > >
> > > >
> > > >
> > > >
> > > >
> > > > ALFRED RATTIE wrot e:
> > > >
> > > > >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 dev elopment 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
> > > > >
> > > > >
> > > > >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
> &g t; > > 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 pr escribed TMECC practices. This ended when I used a
> > > courier service
> > > > to make an immediate delivery. Is there a regrowth issue
> > > associated with
> > > > shipping a nd 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
> > > > >_______________________________________________
> > > > >Compost maillist - Compost at composter.com
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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/list info/compost
> > > >
> > > > This list is a service provided by the US Composting Council.
> > > >
> > > > _______________________________________________
> > > >
> > > >
> > > > Ongoing Sponsors of the USCC Discussion list are:
> &g t; > >
> > > > 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 organ ization.
> > > ; >
> > > > 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
> >
> >
> >
> > _______________________________________________
> & gt; 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 *
>
--
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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