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Should EMTM mudballs be used for treating waterways and seafronts in Penang? By Yap Soo Huey June 2010 TABLE OF CONTENTS INTRODUCTION 1

BACKGROUND 2

REASONS FOR CONCERN A. Positive Results Require Informed Planning 3B. Impact on Microbial Biodiversity 5C. Myths and Lack of Impartial Evidence 6D. Dangers of False Positives 9

i. Examples of possible false positives due to microbial activity 9ii. Possible false positives and negative impacts of EMTM mudball components 10iii. Risk of Complacency 10

E. How is EMTM Different from Standard Bioremediation 11F. Infinite Financial Cost of EMTM 12

RECOMMENDATIONS 12Why monitor use of EMTM in Penang waters? 13Who should be involved? 13Where should monitoring sites be set up? 13When should monitoring take place? 14What parameters should be monitored? 15How can monitoring be achieved? 16

CONCLUSION 17

NOTES 17

ACKNOWLEDGEMENTS 18

BIBLIOGRAPHY 18 INTRODUCTION EMTM technology has been adopted by the Malaysian state of Penang as a cheap and rapid method of reversing the decrepit state of its waterways and popular coastlines. “Effective Microorganisms” or EMTM is a commercial mix†,1,2 of microorganisms that promises to breakdown sludge, purify water and return life to polluted waters. As part of the Penang Government Initiative for Environmental Management (PGI-EM)3, EMTM was used in 2009 in several projects sponsored by civil society groups or corporate social responsibility (CSR) programs, including in Sungai Kelian in Tanjung Bungah4,5, Parit 4 in Bukit Mertajam6,7, Sungai Mas in Batu Ferringhi8,9, Sungai Pinang in Georgetown5,10, Sungai Juru in Seberang Perai11 and the northeastern island coastline along Pesiaran Gurney12. Continuation of some of these projects and commencement of other EMTM projects are expected to continue into the future. Despite the Penang state government’s endorsement3,13,14 of EMTM technology, the use of EMTM to treat Penang waters has sparked lively debate. On the one hand, the benefit and promise of

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EMTM are multi-fold. Firstly, treatment of Sungai Kelian has been lauded by proponents as a stunning success4,13,15, and therefore, is reported5 via mainstream media as evidence that EMTM is an effective alternative to conventional treatment methods that may involve dredging of rivers and removal of pollutants for off-site decontamination. Secondly, the cost of a one-time addition of EMTM into target sites is cheaper and may produce more rapid result than conventional methods. Thirdly, use of EMTM is more plain and attractive to the general public compared with conventional methods that usually require complex study of treatment site and more involved effort by qualified personnel. EMTM is applied to waters by mixing EMTM activated in 5% molasses solution with soil (clay or red earth) and fermented sawdust/bran, and then forming the mixture into “mudballs” that are allowed to dry before being thrown by hand into target sites4,14. EMTM projects have engaged communities by getting people together for EMTM mudball making sessions and to collectively throw these mudballs into target sites. Fourthly and perhaps most significantly, the attractiveness of using EMTM has garnered considerable publicity3,5-12,14,15, thereby raising public awareness of environmental concerns and generating invaluable community participation and even sense of ownership in addressing environmental problems. On the other hand, EMTM is plagued by naysayers whose reasons for concern include the lack of transparency and lack of scientific credibility of EMTM technology, the enabling of negligence from addressing sources of pollution, and the concern that EMTM effects are only temporary so EMTM products will have to be continually used in Penang homes and industries indefinitely or continue to be added at regular intervals into Penang waters. The aim of this review is to (1) provide scientific background for EMTM technology and microbial treatment of polluted waters, (2) explain potential risks of EMTM to Penang, and (3) make recommendations to waylay concerns. Wherever possible, statements made are referenced to publicly accessible information and links are provided in the ‘Bibliography’. 1. BACKGROUND Terms “Effective Microorganisms”, “EM” and “EM Technology” refer to a proprietary blend†,1,2 of microorganisms developed by horticulturist Dr Teruo Higa‡. The EM Research Organisation (EMRO) was founded by Dr Higa in 1994 to manage EMTM trademarks and intellectual property of EMTM products and technology18. EMTM products are sold internationally through EMRO partner organisations and its licensed distributors19. In Penang, EMTM is actively marketed by EMTM consultancy company EM AdminS and its director Mr Soo Lee Choo5,15. Mr Soo is a committee member in the PGI-EM taskforce set up to monitor use of EMTM in Penang3. EMTM was developed by researching combinations of microorganisms obtained from the Horticultural Laboratory of Ryukyus University in Okinawa, Japan20,21. The microbial combination patented as EMTM was developed to reduce the need for fertilizers and pesticides in agriculture20-22. In simple terms, the 3 key fundamental principles for the use of EMTM in agriculture are22:

i. Microorganisms in EMTM facilitate breakdown of organic matter and other insoluble sources of nutrients, and converts nitrogen from air to ammonia for use by plants, thereby making plant nutrients in the soil more readily absorbable and reducing the need for chemical fertilizers. [Note: Existing microorganisms in normal unfertilized and untreated soil are normally sufficient to carry out these reactions, so addition of EMTM is only strictly necessary if a healthy microbial population is not present. Use of EMTM disturbs balance in the existing

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microbial population and establishes EMTM as the dominant population. Higa and Patterson (1994) clearly state that the aim of EMTM technology is to dominate and control the microbial population in soil and if EMTM is not applied at a sufficiently high dose, they “will have little or no effect”.]

ii. By becoming the dominant microbial population in soil, EMTM competes with and suppresses the growth of other microorganisms, which includes harmful and less desirable microorganisms, and thereby reducing the need for pesticides. [Note: As above, a sufficiently high dose of EMTM is required.]

iii. Higa and Patterson (1994) concede that if agriculture was carried out sustainably (ie. without over-taxing the land), there should already be an abundance of nutrients readily available for plants that can be naturally recycled by existing populations of microorganisms in soil without the need for EMTM. They argue, however, that these ideal conditions may only occur in small-scale farming and/or where crop-rotation is practiced, whereas the present day purpose for agriculture is to economically maximize yield from land throughout the year.

The rationale for using EMTM to treat polluted waters is that microorganisms may degrade sludge and wastes as part of their growth. The use of microorganisms to treat pollution is not a novel concept. The same principle is foundation for processes known as ‘bioremediation’§. Bioremediation processes have been informally practiced since the early 1900s, and recognised for effective treatment of contaminated materials since early 1980s. High profile examples of bioremediation are reviewed by Swannell, Lee and McDonagh (1996)23. Conventional bioremediation practices are now well-accepted and have resulted in a wealth of excellent scientific information, refined understanding and technical expertise with well-documented track-record of success. Documentation of EMTM technology is discussed in Section C. 2. REASONS FOR CONCERN A) Positive Results Require Informed Planning As explained above, EMTM has little to no impact if its application is insufficient. For EMTM to establish itself, it has to be able to:

- adapt to and/or convert the environment where it is introduced, as well as - compete with and ultimately dominate over pre-existing microbial populations.

Various factors affect how much and how often EMTM should be applied to be effective. These include (i). Composition of EMTM and (ii). Environmental Factors.

i. Composition†1,2 of EMTM:

a. Lactobacilli/Lactococci (L. plantarum, L. casei and L. Lactis)24-26: The 3 lactic acid bacteria species reported to be part of the EMTM mixture are widely used in the food industry and known for their tolerability of a wide range of pH and temperatures. This improves the likelihood of their survival in some environments, but the ease of establishing themselves and/or persisting in an environment is still dependent on a combination of environmental factors.

[Note: Lactobacilli/Lactococci, also known as “lactic acid bacteria”, produce lactic acid as they grow. They are used in many industrial purposes to acidify (reduce pH) of the environment into which they have been introduced. Their effect on acidity may alter the

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environment so it becomes less ideal for other microorganisms and thus more favorable for themselves and microorganisms that are accustomed to growing with them, eg. other EMTM microorganisms.]

b. Rhodopseudomonas palustris27 and Rhodobacter spaeroides28 are phototrophic bacteria known for their ability to use a variety of nutrient sources, which, as for lactobacilli/lactococci above, improves their likelihood of survival but still dependent on the overall combination of environmental factors.

c. Candida utilis29 and Saccharomyces cerevisiae30 are common yeasts used in the food industry and have relatively quick growth rates. The likelihood of their survival is improved when they are introduced as part of EMTM and have been adapted to thrive within the EMTM mixture.

[Note: Microorganisms that are cultured (have “grown up”) together learn to adapt to each other’s presence. As analogy, a group of individuals who have become friends over time will compete better at a team challenge compared to a group of strangers who will have to make more effort to work as a team and avoid conflict. Growing all the above EMTM microorganisms together enhances their ability to survive when they are introduced together. Nonetheless, survivability is still subject to environmental factors.]

ii. Environmental Factors (eg. pH, temperature, salinity, oxygen density, redox potential,

concentrations of preferred nutrients, concentrations of co-substrates and presence of toxicants) affect the survivability and persistence of any single species or combination of species of microorganisms introduced into an environment. Microorganisms that have been introduced into an environment are usually less able to grow in that environment compared to indigenous microbial populations or microorganisms that have had time to gradually adapt to environmental changes. An exception is if the introduced microorganisms have traits that particularly favour specific environmental factors and give them an advantage over pre-existing populations.

In response to a statewide campaign that saw the release of one million EMTM mudballs into Penang waters on 8th August 2009, which included the tossing of 200,000 EMTM mudballs into the Pesiaran Gurney seafront, questions were raised about the ability of EMTM to survive sea water salinity. Speculations include that EMTM microorganisms would burst due to osmotic pressure when tossed into salty seawater. Unfortunately, these speculations cannot be confirmed or denied without appropriate laboratory testing. However, it is possible to reason that these naysayers may be wrong. The average salinity of seawater is 3.5%, mostly made up of sodium chloride (NaCl) ions31. L. plantarum, L. casei and L. lactis have been found to grow in 4% NaCl32,33. R. palustris and R. spaeroides are also able to overcome salt stress by producing solutes that help balance out osmotic pressure34,35. R. spaeroides has been isolated from coastal mud and even R. spaeroides isolated from fresh water has been shown to grow, albeit more slowly, in 3% salt36. Similarly, Saccharomyces cerevisiae has multiple genes that enable salt tolerance37-39. Additionally, the mixing of EMTM into mudballs may improve survival by providing nutrients and some protection to allow acclimatization to their new environment and opportunity to trigger salt stress response mechanisms. Taken together, some EMTM microorganisms delivered as part of an EMTM mudball may possibly survive in seawater. It is clear that microorganisms selected in the development of EMTM were a clever mix of less fastidious growers (grows easily) that were further cultivated together in the laboratory to enhance group survivability. However, without appropriate testing, it is impossible to determine how many EMTM mudballs are needed to ensure their survival in target waters. If not enough EMTM mudballs were used to sustain EMTM in their new environment, then all hardwork and

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financial costs would be wasted. If sponsors and volunteers are making more EMTM mudballs than necessary, then these extraneous efforts are essentially wasted resources. Projects cannot be resource-effective without adequate knowledge of how much desired outcome is achievable and for how long, relative to amount of resources expended, and these cannot be determined without appropriate monitoring and testing. Szymanski and Patterson (2003) tested the effectiveness of EMTM in reducing domestic sewage sludge in five septic tanks2. To each tank, they added 6 Liters of activated EMTM as a first dose, followed by 3 Liters one week later and subsequently 350 mL doses every week. In the treatment of Sungai Kelian4 in Penang, 10,000 EMTM mudballs were thrown into the river on 25 March 2009, followed by 1,000 EMTM mudballs every week and 1,200 Liters of EMTM every 10 days. Multiple additions of EMTM were used in both cases to enhance likelihood of EMTM survival in their new environment. This is because EMTM in the first dose will struggle most, but the products of their limited growth may gradually change environmental factors to make it more favorable for EMTM in subsequent doses. If a second dose is added before EMTM from the first dose die off and their effects on the environment are reversed, then it would be easier for EMTM from the second dose to survive. Similarly, the timing of each subsequent dose is important to ensure the EMTM microorganisms actually persist in the environment long enough for desired effects to be achieved. Efforts are wasted without knowing optimal timing and dosage. This is especially so in open systems such as waterways and seafronts that are affected by tides, flow and exchanges typical of an open environment. Hence, even if EMTM has the potential to safely and effectively clean polluted Penang waters, it will not be cost-effective without careful tests and monitoring. B) Impact on Microbial Biodiversity Szymanski and Patterson (2003) documented that septic tanks treated with activated EMTM indicated a trend of increasing acidity2, which is likely due at least in part to EMTM lactic acid bacteria. The same study also found that even though conditions (pH, alkalinity and electrical conductivity) in the five septic tanks tested were highly variable at the start of their study, these conditions became similar in all five tanks at the end of their 4-week study and even persisted for a further 2 weeks without more addition of EMTM. This suggests that growth of EMTM had altered conditions in the tank to become optimum for their growth. Unfortunately, this was accompanied by only minimal effect on suspended solids and no clear benefit was derived from the use of EMTM. In other words, in this limited study, EMTM altered conditions in the tanks which would in turn affect growth of other microorganisms, but with no clear benefit to the quality of treated sewage. Whenever an organism is to be introduced into a natural environment, careful study must be conducted to assess its impact on the ecology of the environment. A local example of failure to consider longterm impacts of introducing a non-native species is the introduction of the house crow (Corvus splendens) to Peninsula Malaysia in the late nineteenth century40. C. splendens was introduced to Malaysia as a “cheap and easy” way to biologically control caterpillar populations in plantations. However, upon introduction, their population quickly expanded out of control and they eventually became a pest. Even where an organism is native to an environment, a sudden influx of a single species or a group of species will alter population dynamics in the ecosystem and may result in longterm negative consequences. The risks of introduced/invasive species are now well-recognised.

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However, due to limitations in science (until relatively recently) and because microorganisms are not visible without a microscope, the importance of microbial diversity has been “out of sight, out of mind” and largely ignored, even by environmentalists. Microorganisms are key to maintaining a livable world and are present in every conceivable environment. Humans have been able to derive much use from microorganisms, and yet it is estimated that we only know less than 1% of all bacterial species and less than 5% of all fungal species on Earth41. Microorganisms and their populations are becoming extinct from human activity/interference even before they are identified and their importance understood. In recent years, recognition of the urgency41-43 of exploring and conserving microbial diversity has led to exciting discoveries44-50. As we rapidly approach the anticipated end of the electronics era, use of microorganisms for industrial purposes is expected to dominate and thus richness of microbial diversity represents untapped asset. In fact, the team of Malaysian scientists being trained under a collaborative program between the California Institute for Quantitative Sciences and the Penang-based Malaysian Institute of Pharmaceuticals and Nutraceuticals includes an ocean scientist with interest in bacterial diversity who is being trained to search Malaysian waters for drug potentials51. Unfortunately, the importance of microbial diversity is still poorly appreciated outside the scientific community. In open systems such as rivers and coastlines, microorganisms introduced at any site have potential to impact microbial diversity downstream and even off-shore. Losing indigenous microbial species due to human interference could mean losing a valuable untapped resource. Since EMTM functions by overwhelming existing microbial populations, haphazard and continuous use of EMTM threatens to alter our environment and reduce microbial diversity. EMTM may have utility in agriculture where the very essence of agriculture entails manipulation of nature. However, continuously using EMTM freely and abundantly with poor understanding of its consequences is reckless and foolhardy. Even though EMTM is promoted as consisting of “naturally-occurring microorganisms”, they may not occur naturally in the environments to which they are applied. As an analogy, elephants are naturally-occurring organisms with a wide range of uses, but they do not occur naturally in Penang. Introducing elephants freely and abundantly into Penang would be disastrous for Penang and for the elephants, but likely profitable to those who sell elephants to Penang or sell licenses to people breeding elephants in Penang. C) Myths and Lack of Impartial Evidence Since its commercialization for agricultural use, EMTM has been marketed for non-agricultural uses that include52:

- Spraying EMTM in livestock barns and pens to prevent harmful microorganisms; - Supplementing livestock drinking water with EMTM to promote health; - Adding EMTM to building construction materials to improve building durability and reduce

damage caused by adhesives and organic solvents; - Use of EMTM secondary products to promote human health; - Solid waste and wastewater treatment.

Additionally, during his speech53 at the EMTM Technology Symposium54 in Penang on 7th August 2009 that was attended by Penang Chief Minister YAB Lim Guan Eng and other members of the State Legislative Assembly (ADUN), Dr Teruo Higa states that:

- Spreading EMTM on hillslopes prevents landslides;

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- Drinking may EMTM cure cancer; - Windows will stay clean for a whole year if wiped with EMTM; - Wiping surfaces in your home with EMTM helps convert “bad waves” from computers to

“good waves”; - Plastics will not release dioxins when incinerated if you coat them with EMTM; - Using EMTM at home prevents influenza; - The more EMTM that is used by everyone, the better it is for the world, so everyone should

be using a lot of EMTM freely. The variety of claims made by EMTM proponents is concerning, especially where explanations given do not conform to scientific rationale and evidence of success are mainly from EMRO-linked publications. Even though EMRO purports to have a database55 of >500 research articles and EMRO-related organisations/individuals repeatedly imply that EMTM technology has been tested and verified by multiple groups worldwide, a search of EMRO’s own database on 23rd May 2010 using search terms ‘water’ and ‘waste water’ revealed only 1 and 10 papers respectively. Disappointingly, these papers appear to be cosmetic with reports on only preliminary studies, or descriptions of observations without systematic evaluation, or studies that make firm conclusions without strong evidence or from poorly designed experiments. All papers were linked to EMRO or the EMRO-linked International Nature Farming Research Centre (INFRC). There are little publicly available reports that conclusively support effective non-agricultural use of EMTM and that are independent of Dr Teruo Higa, EMRO or its partner organisations (eg. EM Trading and the INFRC network). The author of this review could only find four reports2,56-58 on non-agricultural use of EMTM that appeared independent of EMRO or its partner organisations:

- Szymanski and Patterson (2003) concluded that EMTM had minimal effect on suspended solids within wastewater treatment systems (septic tanks) over an 8-week sampling period with weekly additions of EMTM up to 4 weeks. They note, however, that addition of EMTM appeared to create a consistency of parameters (pH, electrical conductivity and alkalinity) between septic tanks that suggested that EMTM altered tank conditions to be optimal for their growth. EMTM use resulted in a trend of increasing acidity, which is likely at least partly due to lactic acid bacteria from EMTM.

- Shihab (2010) identified ideal combination ratios of EMTM with lime/alum/ferrous sulphate for sludge dewatering, but did not conclude if the addition of EMTM was useful or feasible to the process. This study reinforces evidence that EMTM increases acidity, as was also observed by Szymanski and Patterson (2003).

- Lurling, Tolman and Euwe (2009) is a well-written but damning report on the effectiveness of EMTM in controlling algae growth for lake restoration. This study demonstrated that not only was EMTM ineffective at preventing algae growth except at very high concentrations that were unfeasible due to excessive sediment load (earth/clay from mudballs) being added into the lake, but addition of EMTM mudballs could instead stimulate increased algae growth by providing nutrients when it would be otherwise limited. Importantly, in addition to increasing acidity, this study also found that the EMTM mudballs released metal contaminants into their target site; including significant amounts of aluminium and copper, and detectable amounts of cadmium, lanthanum and lead.

- Lurling, Tolam and van Oosterhout (2010) further reported that EMTM mudballs released significant amounts of phosphorus and, instead of preventing algae growth, EMTM mudballs enabled algae to continue growing for longer in EMTM mudball-treated lake water compared with lake water without EMTM mudballs. This study also demonstrated that EMTM mudballs had significant effects on oxygen concentration, pH and conductivity of treated lake water.

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They further highlighted that The Centre for Water Management of the Netherlands Ministry of Transport, Public Works and Water Management has estimated that ~21 μg of mercury can be found in each EMTM mudball tested, or about 21 grams of mercury in one million EMTM mudballs. The European Union lists mercury as a priority dangerous compound, so any discharge of mercury into waters is not allowed by European safety standards.

There have been studies that question the effectiveness of EMTM even for agricultural use. These include59-62:

- Anwar et al. (1999) that showed that the use of EMTM was only as effective as a local mixture of Azotobacter and Azospirillium in improving yield of wheat and rice and increasing protein content.

- Hussain Shah, Saleem and Shahih (2001) showed that mixtures of EMTM with nitrogen and phosphate increased grain yield and protein content, but did not demonstrate if EMTM alone could be attributed to effects observed.

- Khaliq, Abbasi and Hussain (2006) showed that EMTM was not effective in increasing cotton yield unless also supplemented by other organic or mineral fertilizers.

- Mayer, Scheid and Oberholzer (2008) reported that EMTM did not improve agricultural yield and soil quality in a 4-year study of arable farming in Swiss temperate climate conditions.

Taken together, the positive results implied by EMRO or its partner organisations are not well-supported by independent published data. It is commonly asserted that scientific communities do not accept EMTM because it consists of a combination of microorganisms, which complicates testing and makes it difficult to attribute effects to any single reaction or species of microorganism. This may have been true when EMTM was first developed in the 1980s. However, science has since advanced to have complex understanding of biological systems as well as the ability to use and manipulate increasingly complex and intricate systems. Now, a myriad of simple analytical chemistry and standard microbiological methods can easily demystify the mechanisms and efficacy of EMTM. Hence, the disinterest in substantiating claims and lack of independent literature on the efficacy of EMTM suggest that its claims are unsubstantiatable and do not justify support from the Penang government. EMTM technology has been portrayed as a revolution that will save the world, and Dr Teruo Higa portrayed as a personification of generosity and benevolence. If this were true, the precise composition† of EMTM should be made public so it can genuinelyψ be produced in abundance by anyone anywhere in the world and its touted benefits can be unequivocally proven. Instead, Dr Higa’s response64 to expert scholars and research institutes worldwide who have tried to prove his claims but failed is that they “simply don’t have the necessary competence and sense of responsibility”. People are simply advised64 to “continue to use (EMTM) until it works” and “to the point where they think it is only natural that things will turn out well”. It is worrisome that, without verifiable evidence of benefit, people are encouraged to “live the ‘EMTM Life’ where EMTM is used as freely as water and the air” and are persuaded that success of EMTM use is dependent on one’s belief and understanding of “the essence of EMTM” 64. In Penang, Dr Higa and EMRO traders have also begun promoting the use of EMTM “in all parts of our lives, so that more and more EMTM would be released into the environment”, which is heralded to be “good for the world”53,54. Publicity garnered through the use of EMTM in Penang

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waters would serve as an excellent marketing tool for promoting ubiquitous use and therefore purchase of EMTM throughout Penang. D) Dangers of False Positives Concerns raised by limited independent studies accentuate the need for reliable monitoring to ensure the safety and efficacy of using EMTM in Penang. However, there appears to be limited effort to ensure characterization of targeted waters prior to EMTM treatment, monitoring of water quality during treatment or verification of success/safety after treatment. The State government appears to be content13 that anecdotal evidence is sufficient. Without testing water samples before EMTM treatment, it would not be possible to characterize pollutants in the water and determine if there are substances present that may require special care. Knowledge of chemical composition of waters prior to treatment is important to identify persistent toxic pollutants that may require close monitoring to ensure they are correctly treated and genuinely removed. Microbial or chemical reactions can cause many pollutants to become more toxic and/or sediment onto the waterbed where they can become more difficult to treat. i. Examples of possible false positives due to microbial activity Polycyclic aromatic hydrocarbons (PAHs) are a class of >100 commonly encountered environmental pollutants that are toxic and can cause cancer65. Hydrogen peroxide (H2O2) produced by lactic acid bacteria in EMTM can oxidize PAHs. However, if oxidation of PAHs is incomplete, intermediary products such as fluorine, dibenzofuran and dibenzothiophene can be even more toxic than PAHs66,67. Without first identifying what pollutants are present in treatment sites, it is impossible to determine what PAHs are present and would need to be monitored to ensure hazardous impacts are averted/removed. Besides PAHs, countless other substances can become more toxic if not treated appropriately. Determination of hazards requires chemical analyses and/or ecotoxicity tests, and cannot be perceived from simply visually inspecting treatment sites. H2O2 is also a bleaching agent that can oxidise organic matter to give water a clearer appearance and remove foul smells68. In addition, R. sphaeroides and S. cerevisiae in EMTM can also produce azoreductase enzyme, which is commonly used to remove colours from wastewater69,70. Together, H2O2 and azoreductase can make waters clearer (eg. as may have occurred in Sungai Kelian4,5) and thus appear “cleaner”, which would be a dangerous illusion if chemical pollutants are still present, or worse, chemical pollutants have become more toxic. It is impossible to discount either risks and determine the safety or “cleanliness” of the EMTM treated water without appropriate testing. In addition to the dangers of microbial activity inadvertently converting pollutants into more toxic compounds, documented2,56-58 acidification of waters by EMTM is a concern because increased acidity in waters can affect the metabolism of organisms that come into the waters and can also change properties of some pollutants. The latter includes ammonium, cyanide and aluminium that become more toxic when waters become acidic71. Even though acidification effects of EMTM may not be significant in open systems such as rivers and coasts, risks cannot be discounted without tests to monitor pH (acidity/alkalinity) and ecotoxicity. ii. Possible false positives and negative impacts of EMTM mudball components

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Other components of EMTM mudballs may also cause false positives or may even cause further damage to target waters. It is important to note that Lurling and colleagues observed releases of metal pollutants (aluminium, copper, cadmium, lanthanum and lead)57 as well as phosphorus58 from EMTM mudballs in their studies, and further reported58 that the Ministry of Transport, Public Works and Water Management in the Netherlands had found mercury in EMTM mudballs, with an estimate of ~21 μg of mercury per EMTM mudball. Whilst the exact composition of EMTM mudballs in the Dutch study may differ from EMTM mudballs used in Penang, these findings highlight the urgency of adequate and independent testing as more EMTM mudballs are being released in Penang. Assumptions of safety without rigorous independent testing may risk safety of Penangites and result in more damage to the Penang environment. Even if EMTM mudballs do not release toxic chemicals into the environment, addition of significant amounts of earth/clay into waterways would have negative consequences. Firstly, they may settle onto the waterbed, and thus affect water levels and create the illusion of cleaner waters by burying sedimented sludge. If buried sludge contains toxic chemicals, they may still pose safety risks, but will be more difficult to treat by being buried deeper into the waterbed. Secondly, earth/clay that are suddenly sedimented onto waterbeds when EMTM mudballs are added would affect any waterbed ecology and may have widespread consequences to overall ecology in Penang waters. Thirdly and most importantly, even if added earth/clay do not impact water level/currents at the sites where EMTM mudballs were added, they would be flushed further downstream where they would inevitably sediment and affect rates of water flow. The unavoidable effect of large amounts of EMTM mudballs on water flow would be a damaging problem, especially in flood-prone Penang. All impacts of EMTM mudballs on our waterways would worsen as more and more mudballs are thrown into Penang waters. It is useful to note that waterways can become clearer simply as result of normal tidal or rainfall cycles that move sludge and organic matter out to sea. This effect occurs independently of EMTM activity, and thus cannot be attributed to successful use of EMTM. However, the throwing of mudballs could assist by breaking up sludge so it becomes easier to flush downstream. If this occurs, even though the target site would appear cleaner, the pollutants are merely shifted away to become a problem at a different site. Waterways may also appear misleadingly clearer if the earth/clay mixture in EMTM mudballs contains salts that can cause humic acids to sediment out of water. Humic acids are yellow/brown acids that can naturally occur in water. Addition of salts can cause humic acids to precipitate72-74 and, like hydrogen peroxide and azoreductase from EMTM microorganisms (see above), this can make waters appear clearer but not necessarily cleaner/safer. Impact of EMTM mudball components (including earth/clay, fermented sawdust/bran and molasses) on nutrient levels in target waters should also be monitored to avoid toxicity (eg. from ammonia), negative effects on ecosystem dynamics and growth of nuisance algae71. Lurling et al. (2010) reported that instead of preventing algae growth, EMTM mudballs allowed algae to continue growing for longer by providing more nutrients58. iii. Risk of Complacency

Widespread publicity and endorsement for use of EMTM in Penang waters are very concerning because they give Penangites unfounded confidence in the quality of the treated water without empirical evidence to discount dangers associated with false positives. Care must then be taken to avoid complacency over its use and complacency from seriously addressing water pollution in Penang.

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For example, even though visual inspection of the EMTM-treated Sungai Kelian site appeared promising, the clarity of water documented >2 months after initial addition of EMTM could be due to a multitude of possibilities (eg. H2O2 oxidation of organic matter, discoloration by azoreductase, burial of sludge, normal movement of sludge further downstream, and precipitation of humic acids) that create a falsely positive illusion of cleaner water without removing hazardous pollutants. When this occurs, the Penang public may be misled to have a false sense of confidence which causes complacency and negligence in curbing sources of pollution. Whilst the possibilities and successes advertised by EMTM are promising, Penangites and the Penang government need to ensure that masked dangers, which may not be immediately obvious, are checked and minimized. Negative impacts of EMTM or EMTM mudballs cannot be discounted without prior characterization of water/ecology in target sites and sufficient independent monitoring of treatment outcomes. Without these assurances, efforts to curb sources of pollution must still be of utmost priority. E) How is EMTM Different from Standard Bioremediation The key difference between the proposed EMTM technology and standard bioremediation practices is the seemingly haphazard and non-specific approach of the EMTM administration in Penang. Acceptable bioremediation practices would require that water from target sites be adequately sampled prior to treatment to identify the nature of pollutants and ascertain the types of chemical reactions that are needed or should be avoided. Prior characterization of water and ecology of environment should be carried out wherever possible, unless prevented by circumstances such as an accidental chemical spill where there was no prior sampling. With knowledge of the nature of pollutants, it is then possible to determine if microorganisms already present in the environment can be stimulated to treat the pollution. Much more often than not, microorganisms can be identified from the existing microbial population that would be capable of treating a variety of pollutants. These microorganisms may not have been efficient at removing pollution due to lack of appropriate nutrients, aeration or co-factors, or the microorganisms themselves may not be present in sufficient numbers. Their ability to treat pollution in their environment can then be augmented by tilling or supplementing the water with required nutrients or co-factors, and/or samples of the microbial population can be cultured in the laboratory to increase numbers of desired microorganisms, which is then reintroduced into the environment. Several studies23 evaluating the use of bioremediation to remove oil spills in marine environments have shown that existing microorganisms can be stimulated by inorganic, organic or natural organic fertilizers or co-factors to successfully treat polluted waters. In fact, studies have shown that stimulating existing microorganisms to treat pollution may have a greater effect than introducing foreign microorganisms, and with lesser impact on the existing ecosystem if care is taken to avoid excessive stimulation. See Swannell, Lee and McDonagh (1996) for a review of these studies. EMTM microorganisms such as L. plantarum, R. palustris and R. spaeroides have been used in bioremediation practices75-79. However, in standard practice, each would be selected after

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characterization of target waters, decision on clear objectives and careful consideration of options. Adding EMTM may not be necessary if existing strains of microorganisms can be stimulated to treat pollution in their waters. Furthermore, EMTM microorganisms may not be suitable for the types of pollutants present. Decisions in the bioremediation process are made based on knowledge of pollutants and nature of the environment. The use of microorganisms already existing in the environment should be desirable and may even be more cost-effective. The need and decision to seed microorganisms (eg. EMTM) should be dependent on a balance of factors including budget and time constraints, extent of pollution, desired outcome, ecological impact and suitability of environment. Without knowledge of water quality before treatment and careful monitoring during and after treatment, it would be impossible to decide on desired outcome (eg. removal of PAHs) or project endpoint (eg. when a lasting impact may be achieved). Additionally, sponsors of bioremediation projects would normally require accountability of methods used and credible evidence of longterm investment outcome. F) Infinite Financial Cost of EMTM Even if EMTM is successful in treating polluted Penang waters, its effects are only temporary if sources of pollution are not identified and curbed. Continuous pollution will require continuous use of EMTM and therefore endless financial cost. Efforts to remediate waterways and coastlines should emphasize returning the environment to a state where it can continue to sustain itself once pollution is removed. Overuse of EMTM without rigorously curbing sources of pollution will lead to environmental dependence on EMTM (Especially if existing microbial populations are displaced; see Section B). If Penang continues using EMTM until its environment becomes reliant on regular additions of EMTM, then the cumulative cost may be infinite. Why should Penang choose a system that will result in having to regularly (eg. monthly or annually) add large quantities of EMTM into its waters? The cost and manpower of regularly purchasing EMTM, producing EMASψ and adding it into our waters will accumulate. Most importantly, it is an unnecessary cost because natural systems are often able to remediate themselves without any intervention once sources of pollution are removed. Are Penangites choosing a quick-fix solution that comes with longterm burden? Are we choosing a morphine injection (along with all its consequences) instead patiently curing our disease? Current efforts should include long term considerations and considerations for future generations. Penangites have been frustrated with the state of our polluted waterways and coasts for too long. However, in our zeal for a cleaner and greener Penang, we cannot be impatient and our decisions must not burden future generations. 3. RECOMMENDATIONS The Penang government’s commitment to addressing water pollution and efforts made to transform Penang into a ‘Green State’ are refreshingly commendable. After years of neglect, it is understandable that any solution that promises to make polluted Penang waters appear cleaner and smell better would be well-received by both Penangites and the State administration. Due to the decrepit state of many Penang waters, even merely cosmetic

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improvements are of appreciable difference. However, efforts for short term improvement should not risk the long term welfare of Penangites and the Penang environment. Concerns raised in the previous section rationalise the need for independent evaluation of EMTM technology to ensure safety of the Penang people and environment. The United Nations (UN) and the World Health Organization (WHO) provide clear guidelines and a Code of Good Practice (COGP) for the design, planning and implementation of water monitoring programmes80-82. The following recommendations are based on these guidelines. Readers are encouraged to consult the original publications for in-depth information. Why monitor use of EMTM in Penang waters? Despite increasing financial and non-fiscal commitments towards EMTM technology, there have not been studies to determine the extent and durability of its effects. To make matters worse, concerns about the credibility of EMTM technology have not been met with reliable scientific data. On the contrary, the few independent publications2,56-58 on non-agricultural use of EMTM technology suggest that EMTM may adversely impact ecosystems, stimulate undesirable algae growth and may itself pollute waters with significant amounts of metal contaminants (including detection of mercury from EMTM mudballs in the Netherlands). EMTM activity and components of EMTM mudballs are additionally expected to affect water flow and/or may cause pollutants to become more toxic or difficult to treat, while at the same time emboldening false confidence in water quality by making waters appear clearer. Mechanisms for these dangers are discussed throughout Sections 2 A – F above. Even if the objective of using EMTM in Penang waters is simply to give cosmetic improvement and does not require assurance of successful removal of pollutants, the wide range of documented and conjectured risks highlighted in this review provides justification for rigorous independent monitoring to avoid interminable environmental and financial costs as well as health hazards. Who should be involved? Monitoring programmes should include active and genuine representation by all stakeholders, including members of local communities, corporate sponsors and industrial partners, businesses and industries whose activities may affect or be affected by the water quality, local council members, relevant government departments and relevant civil society groups. Design, planning and implementation of monitoring programmes should incorporate interests and concerns of all stakeholders to enable most practical and best possible outcomes. Additionally, in view of doubts over the precedence and scientific credibility of treating waterways and coastlines using EMTM technology, and to address environmental and safety concerns, it is vital that design and oversight of monitoring programmes include unbiased scientific advisors. Ideally, advisory panels should be interdisciplinary and include where possible environmental managers, hydrologists, geomorphologists, hydrogeologists, ecologists, water chemists, meteorologists, microbiologists and expert representation from government agencies (eg. Department of Environment). Where should monitoring sites be set up? Monitoring activities do not give useful information if monitoring sites are inappropriate and/or inconsistent. In order to determine suitable monitoring sites, it is important to have good

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understanding of the area to be monitored. This can be achieved by first acquiring a map of the area and then walking along the water system to determine:

- Water-course, ie. waters (eg. catchment, streams, brooks, canals, ditches, lakes, ponds, other rivers) that discharge into or from the site to be monitored;

- Land topography, which affects how/where precipitation is washed into the water-course; - Dimensions and flow rates, including notation of areas of broadening/narrowing; - Description of environmental conditions (eg. rock composition, vegetation, wildlife, land

slope, distance from salt-bodies); - If groundwater enters the water-course (if knowledge available); - Population and land use in surrounding area (eg. industry, agriculture, construction,

tourism, recreation and urban activities); - Identification of point discharges into the river (eg. sewage, drainage and industrial wastes); - Location of man-made structures in surrounding area (eg. bridges, dams, roads).

Once an understanding of the factors affecting the area and water system is established, suitable monitoring sites can be chosen that are appropriate for the monitoring purpose. For preliminary characterization of the monitoring area, sites may be selected to give information on the variety of conditions in the system. During EMTM treatment, selection of sites both upstream and downstream of where EMTM mudballs were added would allow for differences to be attributed to EMTM mudball activity. The monitoring committee may also decide to determine the effects of EMTM mudballs flushed further downstream on geomorphology of water course. Effects of other point discharges can also be determined by comparing sites upstream and downstream. Sites should be chosen with the purpose of monitoring in mind and after consultation with all stakeholders. An independent expert advisory panel should ensure usefulness of monitoring sites, so that subsequent monitoring efforts are optimized and not wasted. When appropriate sites are chosen, it is important that their precise locations are carefully mapped out so that samples can be taken from the same sites at regular intervals and trends monitored. It must be emphasized that information obtained is only useful if sites monitored have been carefully selected to suit monitoring purposes and the same locations are sampled throughout the monitoring programme. For example, it may be sufficient for some purposes for photographs of monitoring sites to be used for comparisons. However, these photographs should be of the exact same location(s) and captured from the same direction and at the same time of day (to account for diurnal changes). If data gathered or unforeseen circumstances in the course of the monitoring programme suggest a need for monitoring site(s) to be revised, selection of new site(s) should again be made after consultation with stakeholders and the independent advisory panel. It may be useful to define standard guidelines for selection of monitoring sites to enable relevant comparisons between different monitoring areas throughout Penang. When should monitoring take place? It is equally important to understand that tidal cycles and rainfall patterns affect water flow, surface run-off and flush of suspended materials. Hence, weather and water flow information are vital to differentiate clearing effects due to water movement from effects due to EMTM mudballs. The timing of each monitoring activity should take into consideration rainfall and waterway hydrology.

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The monitoring committee must decide whether to monitor regularly (eg. weekly) and make careful record of rainfall volume and patterns between monitoring timepoints, or to monitor regularly as well as during rainfall events. Additionally, different parameters may be monitored at different frequencies; eg. basic parameters such as pH, turbidity, dissolved oxygen and phosphate levels may be monitored daily/weekly, whilst chemical analyses for metals or organic pollutants may only be performed fortnightly/monthly. Frequency of monitoring timepoints may be increased or decreased depending on feasibility, urgency of data relative to water use, and understanding of trends as monitoring programme proceeds. It is also important that monitoring activity is carried out at the same time of day to ensure consistency of diurnal factors, such as tide and water levels, which will affect concentration of parameters measured. Other factors such as time required for sample processing or water flow/discharge patterns should also be considered when deciding sampling time; eg. at sunrise, noon or a specific time in the day. Consistent with the example given in the previous section for monitoring sites, any collection of data, including reference photographs, should be collected at the same time of day and notations made of intermediate events (eg. rainfall) to enable fair comparisons of conditions between different days. What parameters should be monitored? The release of EMTM mudballs into Penang waters requires more rigorous testing compared with conventional methods that are also less invasive (eg. based on stopping sources of pollution to allow natural recovery of the water system, or where pollution is dredged and removed for off-site treatment). This is because there is insufficient knowledge of the consequences and tolerability of adding EMTM mudball components into Penang water systems and insufficient documented precedence of EMTM mudball use for treatment of waterways. Hence, decision to use the non-conventional EMTM mudball method must coincide with plans to ensure sufficient testing and monitoring to avert hidden risks and long term negative consequences. Nonetheless, it is usually not feasible to test all parameters all the time. It is therefore necessary to first conduct a study of the target water to determine source(s) and types of pollution, which will inform selection of parameters that should/can be subsequently monitored. This is also an important prerequisite because it identifies problems that most need to be addressed (eg. detection of a hazardous contaminant), rather than what is most obvious (eg. colour and smell). If preliminary tests of target waters highlight contaminants that require special attention, emphasis should be placed on identifying and stopping sources of these contaminants and EMTM treatment should only be considered if there can be reasonable assurance that EMTM mudballs will remove these contaminants and this assurance must be backed by tests that monitor progress. To further waylay concerns about EMTM technology and reduce the amount of tests needed in monitoring programmes, knowledge of the effects of EMTM mudballs in waters can be expanded. For example, Lurling et al. (2009) tested for compounds released from EMTM mudballs when they disintegrate in water. In their study57, 0.5g of EMTM mudball was added to 100mL of water in triplicate and held in the dark at 22oC for 48hrs. Water filtered out from the suspension was then tested for nutrients and metals using instruments commonly used for analytical chemistry.

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Levels of nutrients and metals were compared against levels in water from similar source that was similarly handled and filtered, but without addition of EMTM mudball material. This study found release of significant amounts of phosphate, aluminium and copper, and detectable amounts of cadmium, lanthanum and lead. Similar experiments would be useful in Penang if EMTM administrators can ensure that EMTM mudballs used throughout Penang are consistently made using the same source of clay/earth and other ingredients. Hence, the simple tests such as those conducted by Lurling and colleagues (2009) can give added assurance that EMTM mudballs themselves will not release contaminants into Penang waters. With expanded knowledge on effects of all EMTM mudball components and good understanding of water characteristics in target sites, an independent expert advisory panel working with stakeholders can determine the types and frequency of tests needed for each treatment site. In addition to chemical and biological tests, the effects of adding large amounts of sediments (via mudballs) on the waterbeds and the geomorphology of waterways must also be considered. It is unavoidable that using EMTM mudballs in Penang waters will require rigorous testing and every plan to use EMTM mudballs must coincide with a monitoring programme. However, better knowledge of EMTM mudball effects and prior characterisation of target waters will allow design of monitoring programmes to be optimized for practical considerations such as budget constraints, manpower, logistics and other feasibility concerns. How can monitoring be achieved? Test and analysis methods, quality control measures, staffing and training, and other framework and logistical considerations are pragmatically described in the UN and WHO guidelines for water monitoring programmes80-82. Readers are referred to these guidelines for details, including elements of good practice82. Structures exist within Penang that allow for high quality monitoring programmes that reflect the technical competency, scientific aptitude and community engagement that is renown of Penang. Groups such as Friends of Sungai Juru <http://www.sungaijuru.com/v2/> and Water Watch Penang <http://www.waterwatchpenang.org/> are evidence that successful water monitoring programmes are possible and foundations already exist within Penang. Experience within these groups is invaluable to inform the design of monitoring programmes throughout Penang. Additionally, Penang is home to University Sains Malaysia (USM), which is recognised by its Accelerated Programme for Excellence (APEX) status as the Malaysian university with highest potential for world-class standing. USM departments including the Centre for Marine and Coastal Studies, the River Engineering and Urban Drainage Research Centre, the School of Industrial Technology, the School of Chemical Sciences and the School of Biological Sciences are locally available access points for laboratory facilities and technical expertise. Collaborations between EMTM administrators, the Penang government and USM researchers would be mutually beneficial, and offer USM researchers enhanced international recognition by demonstrating their research and technical excellence in addressing questions about EMTM technology. EMTM mudball activities that have already taken place demonstrate the readiness and resourcefulness of Penang local communities and corporate sponsors to engage in and collectively endeavour to tackle environmental issues.

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In summary, with sufficient commitment, all components necessary to design, plan and implement monitoring programmes to assure well-being of Penangites, Penang waters and the Penang environment are robust in Penang. CONCLUSION EMTM technology promises so much to so many. It promises the budget-constrained Penang government to clean Penang waters and improve Penang’s Green credentials. It promises corporate sponsors a solution to their environmental woes or an attractive means to fulfill CSR obligations. It promises disgruntled Penangites to remove the eyesore and olfactory stench of polluted waterways and coastlines. It inspires communities with a sense of empowerment to be able to act on pollution that once appeared irreconcilable beyond their means. Nonetheless, this review highlights a myriad of inconvenient risks and caution. Penangites and the Penang government must decide if these risks are acceptable. If unsure, they must determine the severity of these risks by conducting appropriate tests to answer concerns. Penang has a proud history of many firsts. Penangites have a strong and continuing tradition of excellence and community participation. The current State government promises a more Competent, Accountable and Transparent (CAT) administration. As we stand on the verge of being the first Green state in Malaysia, can we afford to relax from urgently addressing concerns that question the well-being of Penangites and the Penang environment? If EMTM technology is the miracle cure for polluted environments, can Penang be the first to provide credible documentation of its success and prove our credentials as a State that embraces science and technology? The use of EMTM to treat Penang waters gives Penangites the ability to show how much more we can achieve as a collective people. NOTES † The exact composition of the EMTM blend is not known, but has been reported to comprise mainly of lactic acid bacteria (Lactobacillus plantarum, L. casei, Lactococcus Lactis), photosynthetic bacteria (Rhodopseudomonas palustris, Rhodobacter spaeroides) and yeasts (Saccharomyces cerevisiae, Candida utilis)1,2. ‡ Dr Teruo Higa16,17 is a horticulturist who graduated from the College of Agriculture at Ryukyus University in Okinawa, Japan. After completing his doctorate at the Agricultural Department of Kyushu University, he returned to Ryukyus University as a lecturer in 1970 and was appointed as Professor of Horticulture in 1982. It was at Ryukyus University where he developed EMTM using microorganisms obtained from the University’s Horticultural Laboratory.

§ More info: http://en.wikipedia.org/wiki/Bioremediation and http://www.accessexcellence.org/LC/ST/st3bg.p hp ψ EMRO provides instructions63 for making “EMTM Activated Solution” (EMAS), which involves incubating EMTM in a medium of diluted molasses to give the consumer 20 times more EMTM solution. This has been stated as evidence that EMRO and its distributors are not profit-driven. However, EMAS cannot be used to make more EMAS, so more original EMTM solution would have to be used each time. This is because EMTM component species have different growth rates and it is moreover easy for the process to be contaminated by numerous other microorganisms, so it is unlikely that the mixture and ratio of microorganisms in resulting EMAS is the same as in original EMTM solution and consistency between different batches of EMAS is likely to be poor.

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ACKNOWLEDGEMENTS The author would like to thank and acknowledge the time and effort of Shane E. Perryman, Amanda Wealands and Suse Hayes for helpful discussions and independent review of the manuscript.

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