LOCAL HEALTH DEPARTMENT - GUIDANCE DOCUMENT

Presence of Total Coliform Bacteria in the Water Supply
at Food Service Establishments

Purpose: To provide procedural guidelines to be followed by local health departments when a food service establishment, under local health department jurisdiction, exceeds the monthly maximum contaminant level (MCL) for total coliform bacteria.

Coliform Bacteria: Coliform bacteria are a group of microscopic organisms commonly found in the environment but are also present in the digestive tract and feces of humans and warm-blooded animals. They are usually present in water that has been contaminated by human or animal waste and are used as indicator organisms in the testing of drinking water quality. These indicator organisms are relatively easy, quick, and inexpensive to test for and are normally absent in properly constructed untreated groundwater well supplies. The presence of these organisms indicates that contamination may be entering the water system. Public water systems are required to periodically monitor their water distribution system for the presence of total coliform bacteria to determine the sanitary quality of the water being provided to the public. Coliform bacteria do not generally cause disease by themselves, however, if they are found to be present in a water sample it is assumed that disease-causing organisms (pathogens) may also be present.

Fecal Coliform/E. Coli Bacteria: Fecal coliforms are bacteria that are associated with human or animal wastes. They usually live in human or animal intestinal tracts, and their presence in drinking water is a strong indication of recent sewage or animal waste contamination. Water contaminated with fecal coliforms should never be consumed.

E. coli (Escherichia coli) bacteria is a group of fecal coliform bacteria commonly found in the intestines of animals and humans. E. coli bacteria is also a strong indication of recent sewage or animal waste contamination. Few E. coli strains cause disease, however, the presence of any E. coli bacteria in a water sample suggests that disease-causing organisms may also be present. One of the E. coli strains that does cause disease is E. coli 0157:H7. A standard laboratory analysis will not identify a particular strain of E. coli bacteria nor is it necessary to do so as part of a routine drinking water analysis. Water contaminated with E. coli bacteria, regardless of the strain, should never be consumed.

Collection of Water Samples: Water samples collected from public water systems for compliance with the water quality monitoring requirements contained in Public Health Code (PHC) Section 19-13-B102(e) must be collected by "technical personnel employed by a DPH [Department of Public Health] approved environmental laboratory under Section 25-40 of the Connecticut General Statutes (CGS), or a DPH certified distribution system operator, or a DPH certified water treatment plant operator, or a sanitarian, or an employee of the DPH, or a person under the direct supervision of either an approved environmental laboratory, a certified distribution system operator, or a certified water treatment plant operator". Water samples collected and dropped off for analysis at a DPH approved environmental laboratory by an individual not meeting these criteria shall not be accepted for compliance purposes.

Laboratory Analysis: Water samples collected from a public water system for compliance with the water quality monitoring requirements contained in PHC Section 19-13-B102(e) must be analyzed by a DPH approved environmental laboratory. The analysis for total coliform bacteria must be conducted using either the membrane filter (MF) technique, or the 10-tube multiple fermentation (MTF) technique, or the presence-absence (P-A) coliform test, or the colilert system.

All water samples that are found to have total coliform bacteria present in them must be analyzed for the presence of E. coli bacteria or fecal coliform bacteria.

Confirmation of Total Coliform Positive Samples: The presence of total coliform bacteria in a single water sample is not an MCL violation. If the analysis of a single compliance sample detects the presence of total coliform bacteria, confirmation testing must be performed. Table 1 summarizes the confirmation testing requirements for small public water systems (less than 1000 persons served daily).

Maximum Contaminant Level (MCL) Violation: The MCL for total coliform bacteria is based on the presence or absence of total coliforms, rather than the coliform density. Compliance is based on the monthly MCL for total coliform bacteria. For public water systems that serve less than 33,001 persons on a daily basis, if more than one water sample collected during a month is total coliform positive, the system has violated the MCL for total coliform bacteria in accordance with PHC Section 19-13-102(e)(6)(B)(ii). A public water system that has only one total coliform positive sample in a month is not in violation of the MCL for total coliform bacteria. Any repeat samples required by PHC Section 19-13-B102(e)(7)(G) will be used to determine compliance with the MCL for total coliform bacteria for the month in which the original total coliform positive sample was collected.

If a public water system exceeds the MCL for total coliform bacteria, and E. coli bacteria or fecal coliform bacteria is also present in any of the samples collected, then this is an acute health risk violation of the MCL for total coliforms.

Reporting Positive E. Coli or Fecal Coliform Bacteria Test Results: If any routine or repeat water sample is E. coli positive or fecal coliform positive, the public water system shall notify the DPH-Drinking Water Section (DWS) by the end of the day on which the system is notified of the positive test results but no later than ninety-six (96) hours from the time of sample in accordance with PHC Section 19-13-B102(e)(7)(I). If the DPH is closed, the system shall notify the DWS by the end of the next business day.

Reporting Total Coliform MCL Violations: Any public water system that has exceeded the MCL for total coliform bacteria shall report the violation to the Department of Public Health's Drinking Water Section (DPH-DWS) and the local director of health (DOH) no later than the end of the next business day after it learns of the violation as required by PHC Section 19-13-B102(h)(1).

Increased Monitoring Requirements for Coliform Bacteria: The monitoring frequency for total coliform bacteria shall be increased to five (5) routine samples per month beginning the month following the month in which the MCL violation occurred. Any reduction in this monitoring requirement for total coliform bacteria must be granted in writing by the DPH-DWS.

Public Notification: A public water system that has exceeded the MCL for total coliform bacteria shall provide notification of the violation to its customers within thirty (30) days after the violation occurs. Notification shall be by hand delivery or by continuous posting in conspicuous places within the area served by the water system. Notification shall be in a manner prescribed by the DPH and shall comply with the specific language in the Code of Federal Regulations (40 CFR 141.32).

A public water system that has an acute risk violation of the MCL for total coliform bacteria (i.e. E. coli bacteria or fecal coliform bacteria also present) shall provide notification of the violation to its customers within twenty-four (24) hours after the violation occurs. Notification shall be by hand delivery or by continuous posting in conspicuous places within the area served by the water system. Notification shall be in a manner prescribed by the DPH and shall comply with the specific language in the Code of Federal Regulations (40 CFR 141.32).

Posting of the public notification form shall continue for as long as the violation exists.

Actions To Be Taken By The Local Director of Health For MCL Violations: When the water supply to a food service establishment exceeds the MCL for total coliform bacteria such food service establishment is in violation of PHC Section 19-13-B42(g) which states; "water supplies serving food service establishments shall be adequate, of safe sanitary quality and from an approved source". Such a violation is a four (4) point demerit item (Item #29 on the form titled Inspection Report Food Service Establishment).

PHC Section 19-13-B42(u) requires (in pertinent part) that if there is one (1) or more four (4) demerit point items in violation the local DOH shall order correction within two (2) weeks. If an immediate and substantial hazard to the public health exists (e.g. acute E. coli bacteria MCL violation), the DOH may order immediate correction. If the correction is not made within the DOH specified time frame, the DOH shall issue a written order to close the food service establishment.

To determine the required corrective actions necessary, the local DOH may consult with the DWS to determine if a sanitary survey has been performed on the water system serving the affected food service establishment and if any PHC violations or other sanitary deficiencies were identified during the sanitary survey. If a sanitary survey has not been performed, the DOH should require that the water system be inspected to determine compliance with PHC Section 19-13-B51. Any violations of the PHC that are identified during the inspection should be required to be corrected in the DOH's order. The local DOH may request DWS engineering staff to assist with these inspections when necessary. During water system inspections, the inspector should determine if permanent water service from an existing regulated Community Public Water System (CPWS) is available to the food service establishment. Where it is feasible to obtain water service from a CPWS, this would be the preferred way to resolve the MCL violation. If such service is obtained, any on-site wells must be physically separated and disconnected from the water supply to the food service establishment. These on-site wells should then be properly abandoned or may be used as a separate water supply for other non-domestic purposes such as irrigation or fire-protection.

During the local DOH specified time frame for correction of the violation, the food service establishment may be allowed to continue the food service operation provided an immediate and substantial hazard to the public health does not exist (e.g. E. coli bacteria not detected). During the correction period the local DOH ensures that either an adequate approved alternate water source is made available and/or a modification in the food service operation, menu, equipment use, handwashing facilities, etc., will provide safe quality water in sufficient quantity and at a sufficient pressure to properly continue the food operation. Some interim measures that the local DOH may require during the correction period include:

1. the use of approved bottled water;
2. the use of a temporary alternate source of drinking water from a DPH approved source;
3. limiting the menu to commercially prewashed/prepared packaged foods;
4. supplementing handwashing by using a chemical hand sanitizing solution;
5. continuing to use well water for hot water and approved chemical sanitizing warewashing devices at required temperatures and sanitizing concentrations
6. treating the well water supply with a disinfection system approved by the DPH DWS;
7. using single service utensils;
8. discarding any ready-to-eat foods previously prepared with contaminated well water (e.g. jello, beverages, etc.);
9. discarding any ice prepared from the well water and providing an approved alternate water source for ice preparation

Additional measures specific to the food service establishment may also be appropriate. The DWS staff engineers and the DPH-Food Protection Program staff are available to discuss these measures with DOH's.

If the water supply at a food service establishment is in violation of the MCL for total coliform and E. coli bacteria is also detected, then the food service establishment shall be immediately ordered closed by the local DOH. The DOH may allow the food service establishment to reopen only after the MCL violation is resolved or after adequate interim measures, as described above, are in place to prevent any public exposure to the contaminated well water supply.

At the end of the ordered two (2) week correction period, if the well water supply is still not in compliance with the MCL for total coliform bacteria, the local DOH should take immediate steps to close the food service establishment unless an evaluation by the DOH determines that the interim measures are effective in temporarily providing a safe adequate source of water, necessary for the food operations. If adequate interim measures are in place, the DOH may permit the food operations to continue until the compliance date, specified by the DOH, who may consult with the DWS, for correcting the well water supply deficiencies.

After the required corrections have been satisfactorily made the entire water system including the well(s), distribution system lines, and all equipment receiving water from the well water supply (e.g. ice machines, beverage machines, etc.) must be adequately disinfected with a disinfecting agent listed by the National Sanitation Foundation (NSF) under Standard 60 or be approved by the Environmental Protection Agency (EPA) for drinking water treatment. Following water system disinfection, a minimum of five (5) water samples must be collected from representative sanitary water taps located in the water distribution system and analyzed for total coliform bacteria at a State approved laboratory. The water distribution system must have no free chlorine residual disinfectant when such sampling occurs. Free chlorine residual levels may be measured in the field using an EPA approved chlorine residual test kit or at the laboratory. Verification by the testing laboratory that no free chlorine residual was detected in the water system must be provided with the test results for total coliform bacteria. If any free chlorine residual is detected in any of the water samples, the test results are considered invalid. For this reason, free chlorine residual levels should be determined in the field prior to sampling and if detected, water samples should not be collected.

The local DOH should keep the DWS informed of any orders or other enforcement actions taken against any food service establishment for a violation of item #29 on the form titled Inspection Report Food Service Establishment. The DWS should also be sent copies of written orders issued for such violations.

Actions to be taken by the DPH-DWS for MCL Violations: The DWS, upon notification from the public water system that they have exceeded the MCL for total coliform bacteria, will provide technical assistance in an attempt to determine potential sources of the bacteria. Such technical assistance shall include a review of any sanitary deficiencies identified in previously conducted sanitary surveys and an explanation of common bacteria sources. If a sanitary survey has not been performed then the DWS will consult with the owner over the phone to see if any potential problems can be identified. The owner will be provided recommendations on securing water professionals who would be able to assist them in attaining compliance with the MCL. The owner will be advised of the public notification requirements and a copy of the public notice will be faxed or sent to the owner for posting. If the public water system has not had a sanitary survey it will be added to the DWS list of systems for which sanitary surveys are considered a high priority. DWS engineers or contracted circuit riders will conduct surveys on such systems as soon as possible.

Once technical assistance has been provided to the public water system, the DWS will call the local health department and inform them of the MCL violation, any water system violations identified in previous sanitary surveys, the nature of technical assistance provided to the public water system, and actions recommended to be taken by the DOH.

Upon receipt of the water quality test results from the public water system, the DWS will issue a formal written violation. The violation letter will provide information on the required actions that must be taken including, but not limited to, the public notification requirements and measures that must be taken to resolve the violation. Failure to comply with the written violation may result in further enforcement actions initiated by the DWS which may include civil penalties. Copies of all violations letters issued to public water systems by the DWS will be sent to the local DOH.

Water Treatment Systems: Water treatment systems used for continuous disinfection of the public water system require the review and approval of the DWS. Such treatment systems shall not be considered a substitute for the correction of violations of PHC Section 19-13-B51. Continuous disinfection systems are considered to be a "last resort" after the water system has been brought up to PHC standards, the water system has been disinfected, and bacteriological contamination is still present. When continuous disinfection systems are necessary, it is the responsibility of the owner of the public water system to submit plans and specifications to the DWS for review and approval under PHC Section 19-13-B102(d)(2) prior to any installation. The DWS will review the submission of water treatment system plans and specifications within 10 working days of receipt.

Typical continuous disinfection systems that may be considered for approval include:

1. Ultraviolet light systems
2. Ozonation systems
3. Chlorination systems

Operational constraints of ultraviolet light due to certain levels of minerals in the raw well water may require the installation of additional treatment equipment. Minerals of concern include iron, manganese, and calcium/magnesium hardness. Chlorination and ozonation systems may also require additional water storage facilities to allow for the necessary contact time of water with the disinfectant.

Water treatment components shall comply with National Sanitation Foundation (NSF) Standard 61 and water treatment chemicals shall comply with NSF Standard 60 or be approved by the Environmental Protection Agency (EPA) for drinking water treatment. The design of water treatment facilities shall comply with the DWS's manual titled Guidelines for the Design and Operation of Public Water System Treatment, Works, and Sources.