18 



The misleading implication is that pollution is greater in a State 

 with closed beaches, while, in fact, the real difference is inconsist- 

 ent standards. 



The scientific basis for the identification and evaluation of indi- 

 cators of human health risks is relatively sparse. In a series of 

 studies done in the 1970's and early 1980's, involving swimmers at 

 a number of beaches in the U.S. and elsewhere, concentrations of 

 enterococci bacteria in bathing waters appeared to be the best indi- 

 cator of certain types of disease risk to swimmers. 



In the U.S., the long-established practice has been to base public 

 health criteria on concentrations of fecal coliform bacteria, but in 

 these studies, they were one of the worst indicators. As a result, 

 EPA revised its water quality criteria in 1986. 



However, as you know. States have been slow to adopt EPA's re- 

 vised criteria. EPA is now engaged in a negotiated rulemaking 

 process, as you have just heard, under the existing authority of the 

 Clean Water Act, to mandate the adoption of uniform standards for 

 measuring beach environmental quality. 



However, neither the fecal coliform nor the enterococci stand- 

 ards address many known human health risks from contact with 

 coastal recreational waters, such as skin rashes, ear and eye infec- 

 tions. In addition, these indicators are not themselves the cause of 

 disease. 



Their presence is used to indicate the concurrent presence of mi- 

 crobes that do cause disease, but are very difficult to measure. 

 These difficulties are recognized in Section 5, of H.R. 31, calling on 

 EPA, in cooperation with NOAA, to conduct an ongoing study to 

 develop better indicators for directly detecting the presence of 

 human pathogens in coastal recreational waters. 



NOAA strongly supports this provision but believes that expecta- 

 tions should be realistic in view of the complexity of studies and 

 the very limited funding available to conduct them. 



Prior to the completion of further studies, NOAA is concerned 

 about a provision of Section 3(a) of H.R. 31, which calls for the de- 

 velopment of, "specific numeric criteria calculated to reflect public 

 health risks from short-term increases in pathogens in coastal rec- 

 reational waters." 



For most waterborne human pathogens, especially viruses, we do 

 not have routine methods to measure reliably their concentrations 

 at the levels found in coastal recreation waters. Nor do we know at 

 what concentrations in these waters they pose an appreciable 

 health risk or how the risk varies with environmental factors such 

 as temperature and chemical conditions. Thus, the requirements 

 for specific numeric criteria may focus attention too narrowly on 

 the development of unreliable numbers rather than leaving the 

 flexibility to develop less specific criteria that may better represent 

 the actual situation with regard to our present knowledge. 



While NOAA generally believes that the monitoring provisions 

 of H.R. 31 are reasonable, we remain concerned that the bill not 

 mandate new and expensive monitoring requirements on financial- 

 ly strapped State and local governments which may be unnecessary 

 to achieve the objective of the bill. H.R. 31 appears to provide some 

 flexibility by calling for the establishment of minimum require- 



