[USCC] FW: Re: Fecal Coliform testing issues

Fri Oct 27 18:48:38 CDT 2006

Eliot, Composters,

I would like the Pathogen Reduction phase to finish at the end of the 
heat phase, but still require stabilization as a requirement for a 
'compost'. It seems it should end at the heat phase because that is the 
only place in composting that will kill all the more resistant forms of 
pathogens - it must happen here or it will not happen.
Stabilization can then be completed using vermistabilization (or 
conventional means) and proof of being stabilized via a TMECC CO2 
method. Requiring a FC test after stabilization via heat composting and 
after curing takes place (at sale) seems to disallow others forms of 
stabilizing processes. And once the pathogens have been killed it should 
not matter. IMO
Frank

epsteinee at comcast.net wrote:

>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 
>
>
>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 
>19 Preston Place 
>North Easton, MA 02356 
>Tel: 508-238-1631 
>Cell: 781-603-7151 
>E-mail: epsteinee at comcast.net
>
>-------------- Forwarded Message: -------------- 
>From: epsteinee at comcast.net 
>To: US Composting Council Compost Discussion List <compost at composter.com> 
>Subject: Re: [USCC] Fecal Coliform testing issues 
>Date: Fri, 20 Oct 2006 13:33:47 +0000 
>
>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 
>>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 
>>
>>
>>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 < BR>> 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 Adminis trative/Technical Manager 
>>_______________________________________________ 
>>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 
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>>
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>>    
>>
>_______________________________________________
>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