Hi Lloyd,

For me this is the time of the year when I can 'question authority' and ask
all the tough questions.

Yes, Elaine claims that the stuff Vicki used was 'pre-compost' or 'not
really compost'. Others have said that it did in fact pass through the
regulatory requirements of the composting process, still tested high enough
in E. coli to be not up to OMRI standards, and so was used in the
experiment.

I've forwarded separately Bess's own reply, in which she states that yes,
she used a compost she knew had E.coli in it, since one cannot study what
happens to E. coli if it is absent in the start materials. This is a point
upon which she, and Elaine, and the wide scientific community are in
agreement, spontaneous generation or 'abiogenesis' of E. coli is not going
to happen in a 24 hour compost tea cycle, eh?

So realize, this a common point between Bess and Ingham---both agree that if
no E. coli is present in the start materials, none will be present in the
finished tea. Elaine herself, way back in the spring, said that the compost
task force could simply impose a 'confirmed no E. coli' requirement on the
compost and ingredients for tea, and solve the organic fresh produce problem
that way. Bess agrees.

Elaine provided me with a copy of the Bess study some time ago. It describes
the compost used:

"A manure based compost containing low levels (10-100 MPN/g) of naturally
occurring E. coli was used for all compost tea production. The compost was
produced from approximately equal parts green waste, mushroom compost,
chicken manure and steer manure (Rexius Forest By-Products, Inc., Eugene,
OR) and was intentionally chosen prior to destruction of all E. coli."

This was not hidden, kept from the public or done under cover of darkness,
it was written up right in the 'Materials and Methods' section of the paper.
So where's the big crime?

Yes, no process information on time, temperature or aerobicity of the
treatment of this compost is given. Other people have asserted that it did
go through a time and temperature regime like that required in the NOP
standards.

And, yes, looking at those ingredients we can see a lack of carbon materials
and bulking agents, meaning that depending on moisture content, it is quite
likely that much of the composting process was operating at sub-optimal
oxygen levels, so that the development of the aerobic microbial consortia
that typically take out E. coli was likely to be retarded. This is
guesstimation on my part, since I don't have the exact process parameters in
front of me for this material.

Is it so unlikely though, that someone making compost tea would do their
time and temperature requirements on such a compost, get similar low E. coli
results, and go forward with such material in teamaking?

How many people who make tea are following all of Elaine's advice to the
letter, using continuous read thermometers and oxygen meters for composting,
using a DO meter in their brewer, and all the rest? How many use the
percentages of woody materials she recommends in composting?

I use the woody stuff myself, Lloyd, but I don't have the oxygen meters,
either for the compost or the tea.

Consider the concept of a lottery. In a positive lottery your chances of
winning big are very small, in a negative lottery your chances of losing big
are also very small. People win and lose in such lotteries all the time.

>From a regulator's viewpoint the concern is not with what the top half of
the class is going to do, but the bottom half, the people who miss a key
point, the busy folks who might cut a corner here and there, the
undercapitalized small grower who hopes compost tea is going to solve a
whole bunch of problems but who doesn't have the budget for a full set of
equipment and testing.

As far as 'Brinton's work' is concerned, all the stuff I posted was done
years ago, before the current aerobic compost tea technology came on line.
So, unless he was truly diabolical and did his research in anticipation of
ambushing Elaine several years later, it is pretty hard to claim that he
created a study to discredit compost teas. Everything by Brinton was there
when Elaine wrote the Compost Tea Manual, including the third edition, which
still cites to his research.

Instead, it is best to see this as a genuine difference of opinion between
microbiologists and compost and soil scientists, and to look for common
ground that everyone could accept.

I agree with Elaine's general thesis that aerobic full foodweb compost tea
will reduce rather than grow E. coli. The issue is, then, when the foodweb
is less than full---as would be likely from the compost Bess used....how
likely is that? How often would that occur across the spectrum of organic
growers throughout the US?

Let's say Elaine's thesis holds true in 98% of the cases, and not true in
2%. That would be a phenomenal batting average for a baseball game, but a
real disaster from a food safety POV. What is needed to get to the necessary
level of assurance is a way to test for TQC (Tea Quality Compost) that is
99.99% and then some sure.

I believe this is not that difficult, could bridge the gap that exists
between regulators, their immediate advisors and Elaine, and get us all
something we can work with successfully.

It is one thing to attack Dennis Avery, who is a bought and paid for attack
dog for the chemical industry. It is another to attack people who have made
their life's work in and around the organic and biodynamic sectors, such as
Will Brinton and Vicki Bess.

It is clear that we have had a massive communications breakdown here between
the scientists, regulators, the public and the engaged entrepreneurs and
practitioners. Much of the blame for that surely lies with NOSB, which has
been pretty uncommunicative about all of this, and not open about the
process of gathering information or receiving comments on this subject.

That lack of transparency set me on edge against the process from the
beginning. It still annoys me, and ought to be done away with, so that
people can not only know what the recommendations are that are being made,
but also how they were arrived at, the reasoning and data that underpin
them, and thus be able to cogently challenge those recommendations based on
real knowledge of their foundations.

But, I am convinced at this juncture that there needs to be a Tea Quality
Compost standard for compost tea used on fresh produce within 120 DOH. At
the very least, no E. coli ought to be present.

That's a position that can unite a large number of supporters, and keep the
compost tea movement operating on all cylinders.

I think Elaine's core thesis, full foodweb, full aerobicity, appropriate
nutrients = E.coli elimination or reduction, will be borne out in time. But
since composts can go through the heating phase, still retain low E. coli
populations, and not then carry the full foodweb, the ability to verify
foodweb needs to be solid. If there is much of a window of error there, we
end up playing the negative lottery.

So far I have strongly defended this 'Ingham thesis' against critics who
don't seem to even understand it, which I find really disappointing. In the
interests of trying to get the discussion past the level of 'we are right
and they are evil', however, I am now pointing out that those who don't
understand it, or disagree with it, are also not without reasons to suggest
that poor compost in a compost tea environment could behave not only
ineffectively, but dangerously.

Process standards alone may not get the job done, and it seems like the only
way to build a concensus that will allow compost teas in organic production
is to move to performance standards.

For those unclear on the distinction, time, temperature and aerobicity
standards are process standards; verified no E. coli in the compost is a
performance standard.

Ingham and Bess both seem to feel this would work, now the question is, what
are the other quiet voices in the compost science NOSB community saying, and
why are they saying it?

It should not be like pulling teeth to find out.

And be sure, Lloyd, that if I buy produce grown with compost tea, I will
want a good close look at their practices and procedures.

Frank Teuton


----- Original Message -----
From: "Lloyd Charles" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>
Sent: Thursday, November 14, 2002 6:46 PM
Subject: Re: Search for results of Elaine's testing of bd preps


>
> ----- Original Message -----
> From: Frank Teuton
> >
> > What the Bess study purports to do is falsify Elaine's assertion. Bess
> took
> > 'good enough' compost that had met process standards, put it in a
Growing
> > Solutions 25 brewer, measured DO levels throughout, and was able to grow
> E.
> > coli when simple sugars were added to the mix, under repeated trials.
>
>
> Hi Frank
>               Whats going on here???  Below is direct from one of Elaine's
> messages and she is talking about the material that Bess requested for her
> "test"
>
>                   From:  [EMAIL PROTECTED]
>                   Date:  Thu Oct 17, 2002  4:00 am
>                   Subject:  Re: [compost_tea] Re: Testing & NOP Decision
>
> 'The Rexius material used was pre-compost material.  Jack Hoeck of Rexius
> made that clear to me in an e-mail from him.  He was asked for material
> containing E. coli, and that's what he gave them.'
>
> and again
>                  ' Wil Brinton told me in mid-July (I have the e-mail
still)
> where he told me he'd never heard of 24 hour compost tea.  And he was the
> expert the Compost Task Force was using to tell them about compost tea?'
>
> Somebody is bullsh***ing us!  Who do you pick ?
>
> When I read the Brinton stuff my immediate reaction was this is nothing
more
> than a direct attempt to sabotage the use of compost teas - clearly
biased!!
> Typical science 'set the agenda first then design a test to come up with
the
> appropriate answer'
> Ditto (only more so) for the work done by Brian Duffy (the closed flask
> experiment) totally irrelevant to the brewing of compost tea !!
>
> There is big money and big egos behind this dispute.
> The work of Bess, Brinton and Duffy should go in the trash can where it
> belongs, and some honest testing of the compost tea method be done, using
> quality tested compost, clean materials for feed, and the latest
successful
> aerobic tea brewers, unbiased science - ha! it will never happen eh?
>
> Understand I am not totally opposed to your point of view - there needs to
> be rules - "modern" food transport, processing and distribution methods
> provide almost ideal conditions for pathogen growth - lots of moisture,
> warmth, lack of fresh air, a long time in the supply chain, and as the big
> boys take over organic production there will be problems for sure - which
> will no doubt be blamed on the small farmers, 'backyard operators' same as
> is now the case with the poultry industry.
> Hugh Lovel (as usual) has this right - the best protection for any
consumer
> is to be looking the producer in the eye when the money changes hands!
>
> Cheers
> Lloyd Charles
>
>

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