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4 

 absence of consistent standards, beaches that are closed by one 

 state's standards could be opened by the standards applied by 

 another. The misleading implication is that pollution is greater 

 in the state with closed beaches, while, in fact, the real 

 difference is inconsistent standards. 



The scientific basis for the identification and evaluation of 

 indicators of human health risks is relatively sparse. In a 

 series of studies done in the 1970s and early 1980s, involving 

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

 concentrations of enterococci bacteria in bathing waters appeared 

 to be the best indicator 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 the studies noted they were one of the worst 

 indicators. As a result, EPA revised its water guality criteria 

 in 1986. However, states have been slow to adopt EPA's revised 

 criteria. EPA is now engaged in a Negotiated Rulemaking process 

 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 standards 

 address many known human health risks from contact with coastal 

 recreational waters, such as skin rashes and eye and ear 

 infections. In addition, these indicators are not the cause of 



