Total coliforms are a group of closely related bacteria that, with a few exceptions, are not harmful to

humans. Coliforms are abundant in the feces of warm-blooded animals, but can also be found in aquatic
environments, in soil, and on vegetation. Coliform bacteria may be transported to surface water by run-
off or to ground water by infiltration. Total coliforms are common in ambient water and may be injured
by environmental stresses such as lack of nutrients, and water treatments such as chlorine disinfection,
in a manner similar to most bacterial pathogens and many viral enteric pathogens (including fecal
pathogens).

EPA considers total coliforms to be a useful indicator that a potential pathway exists through which fecal
contamination can enter the distribution system. This is because the absence (versus the presence) of
total coliforms in the distribution system indicates a reduced likelihood that fecal contamination and/or
waterborne pathogens are occurring in the distribution system.

Under the 1989 TCR, each total coliform-positive sample is assayed for either fecal coliforms or E. coli.
Fecal coliform bacteria are a subgroup of total coliforms that traditionally have been associated with fecal
contamination. Since the promulgation of the 1989 TCR, more information and understanding of the
suitability of fecal coliform and E. coli as indicators have become available. Study has shown that the fecal
coliform assay is imprecise and too often captures bacteria that do not originate in the human or mammal
gut (Edberg et al. 2000). On the other hand, E. coli is a more restricted group of coliform bacteria that
almost always originate in the human or animal gut (Edberg et al. 2000). Thus, E. coli is a better indicator
of fecal contamination than fecal coliforms. The provisions of the RTCR reflect the improved
understanding of the value of total coliforms and E. coli as indicators.

a. Presence of fecal contamination.

Fecal contamination is a very general term that includes all of the organisms found in feces, both
pathogenic and nonpathogenic. Fecal contamination can occur in drinking water both through use and
inadequate treatment of contaminated source water as well as direct intrusion of fecal contamination
into the drinking water distribution system. Lieberman et al. (1994) discuss the general association
between fecal contamination and waterborne pathogens. Biofilms in distribution systems may harbor
waterborne bacterial pathogens and accumulate enteric viruses and parasitic protozoa (Skraber et al.
2005; Helmi et al. 2008). Waterborne pathogens in biofilms may have entered the distribution system as
fecal contamination from humans or animals. Co-occurrence of indicators and waterborne pathogens is
difficult to measure. While the analytical methods approved by EPA to assay for E. coli are able to detect
indicators of fecal contamination, they do not specifically identify most of the pathogenic E. coli strains.
There are at least 700 recognized E. coli strains (Kaper et al. 2004) and about 10 percent of recognized E.
coli strains are pathogenic to humans (Feng 1995; Hussein 2007; Kaper et al. 2004). Pathogenic E. coli
include E. coli O157:H7, which is the primary cause of HUS in the United States (Rangel et al. 2005). The
US Centers for Disease Control and Prevention (CDC) estimates that there are 73,000 cases of illness each
year in the US due to E. coli O157:H7 (Mead et al. 1999). The CDC estimates that about 15 percent of all
reported E. coli O157:H7 cases are due to water contamination (Rangel et al. 2005). Active surveillance by
CDC shows that 6.3 percent of E. coli O157:H7 cases progress to HUS (Griffin and Tauxe 1991; Gould et al.
2009) and about 12 percent of HUS cases result in death within four years (Garg et al. 2003). About 4 to
15 percent of cases are transmitted within households by secondary transmission (Parry and Salmon
1998). Because EPA-approved standard methods for E. coli do not typically identify the presence of the
pathogenic E. coli strains, an E. coli-positive monitoring result is an indicator of fecal contamination but is
not necessarily a measure of waterborne pathogen occurrence. Specialized assays and methods are used
to identify waterborne pathogens, including pathogenic E. coli. One notable exception is the data reported
by Cooley et al. (2007), which showed high concentrations of pathogenic E. coli strains in samples
containing high concentrations of fecal indicator E. coli. These data are from streams and other poor
quality surface waters surrounding California spinach fields associated with the 2006 E. coli O157:H7
foodborne outbreak. Data equivalent to these samples are not available from drinking water samples
collected under the 1989 TCR. Because E. coli is an indicator of fecal contamination (Edberg et al. 2000),
and because of the general association between fecal contamination and waterborne pathogens
(Lieberman et al. 1994; Lieberman et al. 2002), E. coli is a meaningful indicator for fecal contamination
and the potential presence of associated pathogen occurrence.

Coliforms are abundant in the feces of warm-blooded animals, but can also be found in aquatic
environments, in soil, and on vegetation. Coliform bacteria may be transported to surface water by run-
off or to ground water by infiltration.

Total coliforms are a group of closely related bacteria that, with a few exceptions, are not harmful to
humans. Total coliforms are common in ambient water and may be injured by environmental stresses
such as lack of nutrients, and water treatments such as chlorine disinfection, in a manner similar to most
bacterial pathogens and many viral enteric pathogens (including fecal pathogens).

There are three groups of coliform bacteria. Each is an indicator of drinking water quality and each has
a different level of risk. Total coliform is a large collection of different kinds of bacteria. Fecal coliform are
types of total coliform that exist in feces. E. coli is a subgroup of fecal coliform.

Total coliform bacteria are common in the environment (soil or vegetation) and are generally harmless. If
a lab detects only total coliform bacteria in drinking water, the source is probably environmental and fecal
contamination is unlikely. However, if environmental contamination can enter the system, pathogens
could get in too. It is important to find and resolve the source of the contamination.

Fecal coliform bacteria are a subgroup of total coliform bacteria. They exist in the intestines and feces of
people and animals.

E. coli is a subgroup of the fecal coliform group. Most E. coli bacteria are harmless and exist in the
intestines of people and warm-blooded animals. However, some strains can cause illness. The presence
of E. coli in a drinking water sample usually indicates recent fecal contamination. That means there is a
greater risk that pathogens are present.

What if coliform bacteria are found in my water?

When coliform bacteria are found, water systems investigate to find out how the contamination got into
the water. They collect additional water samples and often inspect the entire system. Collecting additional
samples helps determine whether an actual problem exists. If the lab detects bacteria in any of the
additional samples, the initial findings are confirmed.

What if total coliform bacteria are confirmed in my water?

If a lab confirms total coliform bacteria in your drinking water, your water system must conduct an
assessment to find out how the contamination got into the water. If the assessment identifies the cause
of the contamination, the water system can usually correct the problem with repairs, treatment, or
improved operation and maintenance practices. We help water systems resolve problems. When a lab
confirms total coliform bacteria in drinking water, we recommend that the water system notify its
customers as soon as possible. The notice will explain what the system is doing to correct the problem,
when the problem will likely be resolved, and what customers may need to do until then.

What if E. coli are confirmed in my water?

Confirmation of E. coli in a water system indicates recent fecal contamination, which may pose an
immediate health risk to anyone who consumes the water. The water system will issue a health advisory
within 24 hours to alert all water users of a health risk associated with the water supply. The advisory
usually recommends using boiled or bottled water for drinking, preparing food, and brushing teeth. It also
outlines the steps underway to correct the problem and explains when the system expects to resolve the
problem.

Fecal Colifrom Testing

Approved tests for total coliform bacteria include the membrane filter, multiple tube fermentation,
MPN and MMO-MUG ("Colilert") methods. The membrane filter method uses a fine porosity filter
which can retain bacteria. The filter is placed in a petri (culture) dish on a pad with growth
enrichment media (mEndo) and is incubated for 24 hrs at 35 degrees C. Individual bacteria cells
which collect on the filter grow into dome-shaped colonies. The coliform bacteria have a gold-
green sheen, and are counted directly from the dish. Since some other bacteria may develop a
similar color, a confirmation test using more specific media is required. The confirmation
procedure requires an additional 24 to 48 hrs to complete the test for suspected positive total
coliform tests.

The MPN (most probable number) method uses a test tube full of media with a smaller inverted
test tube inside which captures carbon dioxide gas released from the growth of coliform bacteria.
A series of dilutions and replicates are set up, and those producing gas in 24 hrs at 35 degrees
C are counted. A statistical analysis is used to determine the most probable number of bacteria
cells present.