http://www.safetables.org/Policy_&_Outreach/Public_Comments/pc_recycled_water_11_1999.htmlSafe Tables Our Priority is a nonprofit, grassroots organization consisting of victims of foodborne illness, family, friends and concerned individuals who recognize the threat pathogens pose in the U.S. food supply. S.T.O.P.'s mission is to prevent unnecessary illness and loss of life from pathogenic foodborne illness. We count among our members victims of E. coli O157:H7 contaminated meat, lettuce and apple juice; hepatitis A contaminated strawberries; Vibrio vulnificus in oysters; Salmonella contaminated poultry and eggs; and Campylobacter contaminated poultry. In all of these cases, the dangers of potentially contaminated products were known to government. And in all of these cases, inadequate efforts by government to warn consumers failed to protect them from life threatening illnesses. We appreciate this opportunity to comment on California State Department of Health Service's Proposed Criteria for Water Recyling.
S.T.O.P.'s chief concern in addressing water recycling is the potential for contamination of human food and water by pathogens. We strongly support DHS setting strict standards for the processing and application of wastewater. Our concerns lie in four categories:
I. Use of Euphemisms
II. Insufficient categorization of food and animal feed crops
III. Lack of science supporting that secondary wastewater is sufficiently disinfected of pathogens.
IV. Testing for pathogens
Use of Euphemisms: S.T.O.P. is concerned that Department of Health Service's adoption of the terms "recycled" and "recycling" as replacements for the terms "reclaimed" and "reclamation" has been strongly encouraged by industry in an attempt to "market" new applications of reclaimed wastewater to consumers. By adopting such euphemisms, the Department of Health Service's further's industry's interests and not that of California citizens. Consumers who would not tolerate the use of reclaimed wastewater in applications related to food crops might not recognize that "recycled water" is, by DHS' definition, the same thing.
.... New terms that do not clarify issues for consumers but rather obscure the real nature of the issues, should not be adopted. This is the purpose of California's Plain English rules. On page two of the Notice of Proposed Rulemaking for Recycled Water, the Plain English description of recycled water is given as: "cleaned sewage."
Insufficient categorization of food and animal feed crops: If DHS will not require that wastewater be disinfected to the same level as drinking water for irrigation of food and feed crops, S.T.O.P. strongly urges that California mandate the use of disinfected tertiary wastewater in the irrigation of all food and feed crops, and at an absolute minimum, disallow the use of any undisinfected water on any food or animal crops.
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S.T.O.P. is very concerned that in California's support for the application of waste water to food and feed crops, California has little scientific support indicating that secondary "recycled" water has been rendered sufficiently pathogen reduced. Indeed, S.T.O.P. is still looking for data to support the safety of tertiary reclaimed wastewater beyond a very recent report: "Estimating the safety of wastewater reclamation and reuse using enteric virus monitoring data," (Tanaka, Asano, Schroeder, Tchobanoglous; Water Environment Research, Jan/Feb 1998). S.T.O.P. strongly urges that California act to restrict the use of wastewater on food and feed crops until such time as it has data proving that different levels of wastewater has been sufficiently pathogen-reduced.
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The Need for At Least Disinfected Water in Foods that Undergo Commercial Pathogen-Destroying Processing
Current FDA and USDA performance standards for the reduction and elimination of pathogens are based on criteria established by scientific subcommittees based on the likelihood of a food coming into contact with pathogens. These committees have not considered that these foods could be irrigated with human-pathogen contaminated waste water. Indeed, though they attempt to set a standard of safety for elimination methods such as irradiation and pasteurization, committee members work from a premise that they need only establish a level that would cover most reasonable contamination. Scientifically, most "Commercial Pathogen-Destroying" processes can be overwhelmed if the incoming levels of contamination are too high, i.e. a 5-log reduction on a food containing 10-logs of organisms will still leave 5 logs of organisms. In addition, specific human pathogens such as E. coli O157:H7 require very few organisms to produce life threatening illness, less than 10 organisms and potentially as little as a single organism. It is therefore absolutely essential that DHS not presume that commercial processes will eliminate contamination caused by undisinfected waste water without specific science that shows how much contamination is being introduced to the food through its irrigation water in addition to the loads initially estimated by federal advisory committees. Anything less would be set up a vicious cycle of revisions to federal performance standards to incorporate DHS wastewater irrigation as a potential source of significant human pathogen contamination.
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IV. TESTING FOR PATHOGENS
S.T.O.P. strongly supports testing of wastewater for pathogens if DHS plans to allow the application of wastewater that is not treated for pathogens up to drinking water quality standards to food and feed crops. Testing should support DHS' assertion that the wastewater has been sufficiently reduced to contain non-harmful levels of pathogens.
Once again, the Bush M.O. is at work. Arnold has been tutored by his masters. Note the same tactics as Katrina, inadequate airlifting of civilians out of Leabanon, and the mining accident in PA : doublespeak, quiet rule changes, inadequate oversight. All we are missing is the graft.
Where is the federal EPA/FDA and Dept of Agriculture on this?