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disease. Their presence is used to indicate the concurrent 

 presence of microbes that do cause human 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. 

 However, expectations should be realistic. The bill authorizes 

 $1 million for FY 1994 and FY 1995 for the administration of the 

 Act, including this study. Even if the full amount were to be 

 appropriated, it would take some time to complete a study of this 

 nature. 



Prior to completion of further studies, NOAA is concerned about a 

 provision of Section 3(a) which calls for the development of 

 "specific numeric criteria calculated to reflect public health 

 risks from short-term increases in pathogens in coastal 

 recreational waters...." For most water-borne 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 this 

 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 



73-065 0-93-3 



