National Beach Guidance

and Required Performance Criteria 

for Grants, 2014 Edition

EPA-823-B-14-001

JULY 2014 
National Beach Guidance

and Required Performance Criteria

for Grants, 2014 Edition

July 31, 2014
National Beach Guidance

and Required Performance

Criteria for Grants, 2014 Edition

United States Environmental Protection Agency

Office of Water (4305T)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

EPA-823-B-14-001

July 31, 2014
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Contents

Contents

Chapter 1: Introduction ................................................................................................................. 1

1.1 Program and Document Overview ................................................................................... 2

1.1.1 Implementing the BEACH Act ................................................................................4

1.1.2 How to Use This Document .....................................................................................5

1.1.3 How This Document Is Organized ..........................................................................6

1.2 Pathogens ......................................................................................................................... 6

1.3 Fecal Indicators ................................................................................................................ 8

1.4 Health Concerns ............................................................................................................. 10

1.5 Water Quality Criteria and Standards for Bacteria ........................................................ 11

1.5.1 State Implementation of the 2012 Recreational Water Quality Criteria 

(RWQC) .................................................................................................................11

1.5.2 Implementation Guidance ......................................................................................13

1.6 Chapter 1 References ..................................................................................................... 14

Chapter 2: Grants and Required Performance Criteria ............................................................... 18

2.1 BEACH Act Conditions and Requirements Applicable to Section 406 Grants ............ 18

2.2 Performance Criteria ...................................................................................................... 18

2.2.1 Risk-based Beach Evaluation and Classification Process (Performance 

Criterion 1) .............................................................................................................19

2.2.2 Tiered Monitoring Plan (Performance Criterion 2) ...............................................19

2.2.3 Methods and Assessment Procedures (Performance Criterion 3)..........................20

2.2.4 Monitoring Report Submission (Performance Criterion 4) ...................................20

2.2.5 Delegation of Monitoring Responsibilities (Performance Criterion 5) .................20

2.2.6 Public Notification and Risk Communication Plan (Performance Criterion 6) ....20

2.2.7 Actions to Notify the Public (Performance Criterion 7) ........................................21

2.2.8 Notification Report Submission (Performance Criterion 8) ..................................21

2.2.9 Delegation of Notification Responsibilities (Performance Criterion 9) ................21

2.2.10 Adoption of New or Revised WQS and Identification and Use of a Beach 

Notification Threshold (Performance Criterion 10) ..............................................21

2.2.11 Public Evaluation of Program (Performance Criterion 11) ...................................21

2.3 Additional Grant Information ........................................................................................ 22

2.3.1 Grant Program Phases ............................................................................................22

2.3.2 Eligibility for Grants ..............................................................................................22

2.3.3 Selection Process ...................................................................................................23

2.3.4 Grant Award Process .............................................................................................23

Chapter 3: Risk-based Beach Evaluation and Classification Process ......................................... 24

3.1 Performance Criterion .................................................................................................... 24

3.2 Step 1: Identify Coastal Recreation Waters ................................................................... 25

3.2.1 Coastal Versus Noncoastal Waters ........................................................................26

July 31, 2014 iii
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Contents

3.2.2 Designated Uses of Water Bodies..........................................................................27

3.3 Step 2: Identify “BEACH Act” Beaches ....................................................................... 27

3.4 Step 3: Characterize the Beach to Determine Risk and Use .......................................... 28

3.4.1 Assess Potential Sources of Contamination and Risks ..........................................29

3.4.2 Determine Use of the Beach ..................................................................................33

3.5 Step 4: Rank Beaches by Tiers ...................................................................................... 34

3.5.1 Other Factors ..........................................................................................................34

3.5.2 Tiered Approach ....................................................................................................35

3.6 Step 5: List of Beaches—Classify Beaches into “Program” Versus “Non-program” 

Beaches and Incorporate Them into a Final State List of Beaches ................................ 35

3.6.1 Initial Submission to EPA ......................................................................................37

3.6.2 Revising and Updating the List of Beaches ...........................................................37

3.7 Federal Beaches ............................................................................................................. 37

3.8 Chapter 3 References ..................................................................................................... 37

Chapter 4: Beach Monitoring ...................................................................................................... 39

4.1 Performance Criteria ...................................................................................................... 40

4.2 Developing a Tiered Monitoring Plan (Performance Criterion 2) ................................. 42

4.2.1 Goal and Key Considerations ................................................................................42

4.2.2 Tiered Monitoring Plan ..........................................................................................44

4.2.3 Quality Management System Requirements for Performance Criterion 2 ............45

4.3 Factors to Consider When Developing a Monitoring Plan ............................................ 47

4.3.1 Variability of Beach Water Quality .......................................................................47

4.3.2 Recommended Monitoring ....................................................................................50

4.3.3 Administering a Monitoring Program ....................................................................56

4.4 Methods and Assessment Procedures (Performance Criterion 3).................................. 59

4.4.1 EPA-Approved or Validated Analytical Methods .................................................59

4.4.2 Selection of Analytical Methods: Culture versus qPCR ........................................61

4.4.3 Using Other Methods or Indicators for Developing Site-specific WQS ...............64

4.5 Monitoring Report Submission (Performance Criterion 4) ........................................... 65

4.5.1 Data Validation and Verification Recommendations ............................................66

4.6 Use of Predictive Tools in Beach Monitoring Programs ............................................... 67

4.6.1 Statistical Models ...................................................................................................68

4.6.2 Rainfall-based Beach Notification Threshold ........................................................70

4.6.3 Notification Protocols ............................................................................................70

4.6.4 Deterministic Models .............................................................................................70

4.6.5 Determining Exceedances Using Predictive Models .............................................71

4.7 The 2012 RWQC Provide Context for Beach Monitoring Programs ............................ 71

4.7.1 2012 Recreational Water Quality Criteria .............................................................71

4.7.2 Threshold Values for Beach Notification Actions .................................................73

July 31, 2014 iv
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Contents

4.7.3 Implementation Requirements for Adopting the 2012 RWQC into State and 

Tribal WQS and Identifying and Using a Beach Notification Threshold 

(Performance Criterion 10) ....................................................................................76

4.7.4 Use of RWQC in Identifying CWA Section 303(d) Impaired Waters ..................77

4.8 Delegation of Monitoring Responsibilities (Performance Criterion 5) ......................... 78

4.9 Chapter 4 References ..................................................................................................... 78

Chapter 5: Public Notification and Risk Communication ........................................................... 83

5.1 Performance Criteria ...................................................................................................... 83

5.2 Public Notification and Risk Communication Plan (Performance Criterion 6) ............ 85

5.2.1 Creating a Risk Communication Strategy ..............................................................85

5.2.2 Addressing Needs and Establishing Trust .............................................................87

5.2.3 Crafting Beach Notifications .................................................................................88

5.2.4 Evaluating Public Notification and Risk Communication Plans ...........................91

5.2.5 When to Notify EPA and Local Governments ......................................................92

5.3 When to Issue and Remove a Notification .................................................................... 92

5.3.1 When to Issue a Notification..................................................................................92

5.3.2 When to Remove a Notification ............................................................................93

5.4 Actions to Notify the Public (Performance Criterion 7) ................................................ 93

5.4.1 Beach Signs ............................................................................................................93

5.4.2 Traditional Mass Media .........................................................................................97

5.4.3 Methods that Allow Stakeholders to Anonymously Seek Out Information ..........97

5.4.4 Methods that Rely on Stakeholders to Provide Contact Information to 

Receive Information...............................................................................................98

5.5 Notification Report Submission (Performance Criterion 8) ........................................ 100

5.6 Delegation of Notification Responsibilities (Performance Criterion 9) ...................... 100

5.7 Chapter 5 References ................................................................................................... 102

July 31, 2014 v 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Contents

Tables

Table 1-1. Examples of waterborne pathogens in the three groups: bacteria, viruses, and 

protozoans ......................................................................................................................9

Table 2-1. Summary of BEACH Act performance criteria ...........................................................19

Table 2-2. Summary of public evaluation of program performance criterion ...............................22

Table 3-1. Summary of risk-based evaluation and classification process performance 

criterion ........................................................................................................................25

Table 3-2. Example of a List of Beaches .......................................................................................36

Table 4-1. Summary of monitoring performance criteria ..............................................................40

Table 4-2. Example of a tiered monitoring plan ............................................................................44

Table 4-3. Percent of exceedances missed for different sampling frequencies .............................49

Table 4-4. Recommended 2012 RWQC ........................................................................................72

Table 4-5. Beach Action Values (BAVs) ......................................................................................74

Table 4-6. Values for qPCR ...........................................................................................................76

Table 5-1. Performance criteria details ..........................................................................................84

Figures 

Figure 3-1. Step 1: Identify coastal recreation waters. ..................................................................26

Figure 3-2. Coastal and noncoastal waters. ...................................................................................26

Figure 3-3. Step 2: Identify beaches and similar points of access. ................................................27

Figure 3-4. Step 3: Characterize the beach to determine risk and use. ..........................................28

Figure 3-5. Step 4: Rank beaches by tiers......................................................................................34

Figure 3-6. Step 5: Complete the List of Beaches. ........................................................................35

Figure 4-1. Relative contributions to temporal variations in FIB density. (Line length 

indicates duration of influence.) ..................................................................................47

Figure 4-2. Relative contributions to spatial variation at coastal beaches. ....................................50

Figure 4-3. Relative contributions to spatial variation at inland beaches. .....................................50

Figure 5-1. The universal symbol for “No.” ..................................................................................94

July 31, 2014 vi
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Acronyms and Abbreviations

Acronyms and Abbreviations

AFO Animal feeding operation

AOAC Association of Official Analytical Chemists International

APHA American Public Health Association

ASTM American Society for Testing and Materials International 

ATP Alternate Test Procedure

AWWA American Water Works Association

BAV Beach Action Value

BEACH Act Beaches Environmental Assessment and Coastal Health Act of 2000 

BEACON Beach Advisory and Closing Online Notification 

CAFO Concentrated animal feeding operation 

CCE Calibrator cell equivalents

CFU Colony-forming unit(s)

CFR Code of Federal Regulations

CPD Chicago Park District

CSO Combined sewer overflow 

CWA Clean Water Act

DOHMH [New York City] Department of Health and Mental Hygiene 

DQO Data quality objective 

EMPACT Environmental Monitoring for Public Access and Community Tracking 

EPA [United States] Environmental Protection Agency 

FIB Fecal indicator bacteria

FR Federal Register

FY Fiscal year

GM Geometric mean

IAC Internal amplification control

IMS/ATP Immunomagnetic separation/adenosine triphosphate 

mL Milliliter

MPN Most probable number 

MST Microbial source tracking

NEEAR National Epidemiologic and Environmental Assessment of Recreational 

Water

July 31, 2014 vii
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Acronyms and Abbreviations

NGI NEEAR gastrointestinal illness

NOAA National Oceanic and Atmospheric Administration

NPDES National Pollutant Discharge Elimination System

NRC National Research Council

OW Office of Water

POTW Publicly owned treatment works

QA Quality assurance

QAPP Quality assurance project plan

QC Quality control 

QMP Quality management plan

QMRA Quantitative microbial risk assessment

qPCR Quantitative polymerase chain reaction

RSS Real Simple Syndication

RWQC Recreational Water Quality Criteria

SCCWRP Southern California Coastal Water Research Project 

SOP Standard operating procedure 

SPC Sample processing control 

SSM Single sample maximum

STORET EPA’s national database for STORage and RETrieval (STORET) of water 

quality data

STV Statistical Threshold Value

TMDL Total maximum daily load

USGS United States Geological Survey 

WHO World Health Organization

WQS Water quality standard(s)

WQX Water Quality eXchange

July 31, 2014 viii
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

This document discusses the required performance criteria for beach monitoring and notification 

programs for which the U.S. Environmental Protection Agency (EPA) provides implementation 

grants under Clean Water Act (CWA) section 406(b). It also provides additional guidance

(recommendations) for grant recipients.

This document might also be used as nonbinding guidance for states, tribes, and local 

governments that do not have a CWA section 406(b) grant, but want to develop and implement 

beach monitoring and notification programs. This document contains a wealth of useful

information and many best management practices that states, tribes, and local governments

might want to follow. 

The general approach and principles described here are also recommended for inland beaches, 

although some modifications might be appropriate.

Chapter 1: Introduction 

The National Beach Guidance and Required Performance Criteria for Grants outlines the 

performance criteria that an eligible coastal or Great Lakes state,1 territorial, tribal, or local 

government must meet to receive grants to implement coastal recreation water monitoring and 

public notification programs under section 406 of the Clean Water Act (CWA), as amended by 

the Beaches Environmental Assessment and Coastal Health Act of 2000 (BEACH Act). Section 

3.2.1 defines the coastal recreation waters covered under the grant program. This document also 

provides useful guidance for both coastal and inland beach monitoring and notification 

programs. The BEACH Act, however, authorizes the award of grant funds to support monitoring 

and notification programs for coastal recreation waters only. 

In 2002 the U.S. Environmental Protection Agency (EPA) published performance criteria for the 

BEACH Act grant program. That document raised the bar for beach monitoring and notification 

programs by standardizing required program elements, while still allowing states sufficient 

flexibility to accommodate their local conditions. Since then, EPA and the states have created a 

strong infrastructure to implement the national and state BEACH Act monitoring and notification 

programs. Together, EPA and the states have built a program that has greatly increased 

consistency among the states as well as the quality, quantity, and timeliness of beach water 

quality data. This information helps beachgoers to make informed decisions about beach-going 

activities and helps beach managers take actions to safeguard the health of their beaches and the 

people using them. 

Today’s beach programs are ready to take the next steps, and following the performance criteria 

and recommendations in this guidance will help them to accomplish that. 

1 For simplicity, throughout the remainder of this document, unless otherwise noted, we use the general term state to 

refer to the 30 coastal and Great Lakes states or local governments and the coastal territories defined in CWA 

section 502 as the Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the Commonwealth 

of the Northern Mariana Islands, and the Trust Territory of the Pacific Islands. Eligible tribes are recognized 

independently and not included in the term state. If certain requirements or recommendations apply in a different 

manner to each governmental entity, the text will specify how they apply. This simplified terminology also applies 

to those entities using this document as nonbinding guidance, e.g., those not receiving CWA section 406(b) grants.

July 31, 2014 1 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

• Consistent with the BEACH Act, the guidance requires states receiving grants under 

CWA section 406 to adopt new or revised recreational water quality standards (WQS). 

State adoption of new or revised standards will put in place the many public health 

protections from the 2012 Recreational Water Quality Criteria (RWQC), including: 

o Addressing a broader range of illness symptoms.

o Better accounting for pollution after heavy rainfall.

o Ensuring equal protection for swimmers in coastal and Great Lakes waters. 

o Encouraging early alerts to beachgoers by identifying a conservative threshold for 

issuing beach notifications (i.e., advisories and closures). 

o Making available a quantitative molecular method (qPCR) that provides analytical 

results in hours. 

o Supporting tailored WQS for site-specific public health protection. 

• The guidance also paves the way for improved beach monitoring and public 

awareness. The performance criteria and recommendations in the guidance will lead 

states into an era characterized by widespread use of sanitary surveys to identify sources 

of fecal pollution; the use of qPCR analysis and predictive modeling that facilitate sameday notification of water quality exceedances; site-specific solutions for protecting public 

health; and timely reporting of water quality results and advisory information for easy 

public access and dissemination. 

1.1 Program and Document Overview

EPA initially published National Beach Guidance and Required Performance Criteria for 

Grants in June 2002. EPA is revising the guidance to accomplish the following: 

• Reflect updated science.

• Incorporate key considerations deriving from EPA’s most recent CWA section 304(a) 

criteria recommendations in the 2012 Recreational Water Quality Criteria (RWQC; 

USEPA 2012b).

• Emphasize using tools such as sanitary surveys in evaluating and classifying beaches.

• Encourage a more comprehensive approach optimizing resources by developing a tiered 

monitoring and notification plan that takes into account new tools, such as modeling and 

rapid methods, and historical information about each beach.

• Update the discussion on beach notification and communication to include tools such as 

social media, websites, and email.

Chapters 3, 4, and 5 of this guidance discuss these changes. 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

Key Changes to This Document from the 2002 Guidance

• Updates the science on pathogens, fecal indicator bacteria (FIB), and health concerns

(sections 1.2, 1.3, and 1.4) and references. 

• Discusses the beach program and the 2012 RWQC (sections 1.5 and 4.7).

• Makes sanitary surveys a central part of the beach classification process (section 3.4).

• Provides detailed guidance on developing the List of Beaches (section 3.6).

• Strengthens the link between prioritizing beaches and developing a tiered monitoring

plan (sections 3.5, 3.6, and 4.2).

• Adds specific requirements to performance criteria 2, 3, 4, and 6 (sections 4.2, 4.4,

4.5, and 5.2, respectively).

• Updates the science on beach water quality monitoring (section 4.3).

• Updates monitoring procedures to include quantitative polymerase chain reaction

(qPCR) (section 4.4.2).

• Expands the discussion on integrating predictive models into monitoring plans (section

4.6).

• Provides guidance on when to issue or remove a notification (section 5.3).

• Discusses new beach notification and communication tools, such as social media,

email, and text messages (section 5.4).

• Adds a new performance criterion, Performance Criterion 10 (section 4.7.3).

The BEACH Act addresses the human health risks associated with water quality and swimming 

or similar water contact activities in coastal recreation waters. The BEACH Act, an amendment 

to the Federal Water Pollution Control Act (commonly known as the Clean Water Act, or CWA), 

addresses pathogens and pathogen indicators2 in coastal recreation waters.

The BEACH Act contains four significant provisions: 

1. The BEACH Act amended the CWA by adding section 303(i), which directs states with

coastal recreation waters to adopt new or revised WQS for pathogens and pathogen

indicators for which EPA had published criteria under CWA section 304(a) (i.e., EPA’s

1986 Bacteria Criteria). Section 303(i) also directs EPA to promulgate standards for

states that fail to establish standards as protective of human health as EPA’s 1986 criteria.

EPA promulgated standards for specific states and territories with the publication of

Water Quality Standards for Coastal and Great Lakes Recreation Waters Final Rule

(40 CFR [Code of Federal Regulations] part 131) in November 2004.

2 The BEACH Act uses the terminology pathogen and pathogen indicators. The BEACH Act defines pathogen 

indicator as “a substance that indicates the potential for human infectious disease” [33 U.S.C. 1362(23)]. Pathogen 

indicators is a broad category of entities (which can include chemical and biological parameters) that can be used to 

indicate the presence of pathogens in water. In the case of BEACH Act implementation, EPA’s current recreational 

water quality recommendations and state WQS are for FIB, which are a subset of the pathogen indicators used 

globally for management of recreational waters. Where appropriate throughout the remainder of this document, FIB 

are referred to specifically when discussing WQS. When a more inclusive discussion of indicators is presented, the 

reference is to pathogen indicators. 

July 31, 2014 3 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

2. The BEACH Act amended the CWA by adding sections 104(v) and 304(a)(9), which 

together require EPA to conduct studies associated with pathogens and human health and 

to publish new or revised CWA section 304(a) criteria for pathogens and pathogen 

indicators on the basis of those studies. EPA completed studies in December 2010 and 

published new or revised criteria for recreation waters in November 2012. 

3. Under section 303(i)(1)(B), states that have coastal recreation waters are directed to adopt 

new or revised WQS for all pathogens and pathogen indicators to which EPA’s new or 

revised section 304(a) criteria are applicable by no later than three years after EPA’s 

publication of the new or revised section 304(a) criteria. 

4. The BEACH Act amended the CWA by adding section 406, which authorizes EPA to 

award grants to states or local governments to develop and implement beach monitoring 

and notification programs. It also requires EPA to maintain state monitoring and 

notification data and make them available to the public. In addition, the BEACH Act 

amended section 518(e) of the CWA to authorize EPA to treat tribes in the same manner 

as states for the purposes of section 406; therefore, EPA is authorized to award grants to 

tribes.

To read the full text of the BEACH Act, go to 

http://water.epa.gov/lawsregs/lawsguidance/beachrules/act.cfm. 

1.1.1 Implementing the BEACH Act

Since the passage of the BEACH Act in 2000, EPA and states have created a strong 

infrastructure to implement national and state BEACH Act monitoring and notification 

programs. Significant progress has been made in providing more public health protection at 

beaches.

• Beach grants. Beginning with development grants in fiscal year (FY) 2001, EPA has 

continued to provide implementation grants to states and tribes to monitor their beaches 

and notify the public of exceedances or likely exceedances of WQS for pathogens and 

pathogen indicators. Since 2001, EPA has made available nearly $130 million in grants to 

38 eligible grantees (30 states, five territories, and three tribes).

• State beach program infrastructure. States are the primary implementers of beach 

monitoring and notification programs funded under the BEACH Act. Since 2000, they 

have significantly refined, improved, and upgraded their beach programs, often through 

the use of innovative approaches. The number of monitored beaches more than doubled 

between 1997 and 2012. Since 2005, monitored beaches have been open for an average 

of 95 percent of the available beach days during each beach season.

Many states are using innovative tools such as predictive models and rapid analytical 

methods to provide faster, more accurate public notification of exceedances or likely 

exceedances of applicable WQS for pathogen indicators. They have improved beach 

notification signage and outreach and communication with the public. Some states issue 

notifications in English and Spanish or use color-coded systems to indicate differences in 

risk. Many states now provide real-time beach water quality results and beach status 

information through the Internet so the public can be better informed. 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

• Sound science and new program tools. In 2008 EPA published the Great Lakes Beach 

Sanitary Survey User Manual (USEPA 2008) and sanitary survey forms to encourage 

using this tool to characterize beach environments and identify likely sources of 

pollution. Through the Great Lakes Restoration Initiative, states conducted more than 

400 sanitary surveys at Great Lakes beaches. On the basis of the findings of the sanitary 

surveys, mitigation measures are currently being implemented at several Great Lakes 

beaches to reduce or eliminate contamination.

In 2013 EPA published the Marine Beach Sanitary Survey User Manual (USEPA 2013) 

to help beach managers in coastal states synthesize beach and watershed information

from the survey to improve water quality for swimming and develop models to predict 

daily water quality. The marine survey forms include detailed questions on winds, tides, 

and other characteristics that affect marine beaches; these were not included on the 

survey forms for the Great Lakes.

EPA also developed and implemented a comprehensive research plan that includes the 

development and validation of rapid molecular methods for quantifying FIB to allow for 

rapid beach notification, the refinement and validation of predictive models for fresh and 

marine waters, and large-scale epidemiological studies in fresh and marine waters to 

determine the relationship between fecal indicator levels and illness.

• BEACON. EPA created the Beach Advisory and Closing Online Notification (BEACON) 

system to meet the BEACH Act requirement that EPA establish and maintain a publicly 

available database of pollution occurrences for coastal recreation waters. In January 2012 

EPA launched BEACON 2.0, which provides access to mapped locational data (beaches 

and monitoring stations); monitoring results (pathogen indicators, algae, salinity, and 

more); and notification data (advisories and closures). For the first time, beachgoers can 

view reports containing both notification and water quality monitoring data. To access 

BEACON, go to http://watersgeo.epa.gov/BEACON2/about.html. 

1.1.2 How to Use This Document

This document replaces the June 2002 National Beach Guidance and Required Performance 

Criteria for Grants and sets forth performance criteria for (1) monitoring and assessing coastal 

recreation waters adjacent to beaches (or similar points of access used by the public) to 

determine whether there are exceedances of applicable WQS for pathogen indicators and 

(2) promptly notifying the public of any exceedance or likely exceedance of applicable WQS for 

pathogen indicators for coastal recreation waters. EPA is required to publish performance criteria 

under CWA section 406(a). Section 406(b) authorizes EPA to award grants to states and tribes to 

implement monitoring and notification programs, but only if the program meets certain 

requirements. (See CWA section 406(b) and (c).) One such requirement is that monitoring and 

notification programs must be consistent with the performance criteria published under CWA 

section 406(a). 

EPA will use the performance criteria to determine whether a monitoring and notification 

program is eligible for an implementation grant under CWA section 406(b). This document 

includes required performance criteria, general EPA grant rules under 40 CFR part 31, and 

nonbinding recommendations. This document can serve as a reference guide on how to develop 

and conduct a beach monitoring and notification program that is not funded by a CWA section 

July 31, 2014 5 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

406(b) grant. It provides information on classifying recreational waters, performing monitoring 

and assessment, and notifying the public about beach advisories. This information is useful to 

beach or program managers of all beaches whether they are adjacent to coastal recreation waters 

or other waters. For states, tribes, and local governments without CWA 406(b) grants, the 

requirements this document describes would not be binding, but they can be used as 

recommendations to develop and implement effective beach monitoring and notification 

programs. 

1.1.3 How This Document Is Organized

• Chapter 1 discusses human health concerns associated with exposure to pathogens and 

discusses the establishment of WQS for pathogen indicators, specifically FIB. 

• Chapter 2 summarizes the basic requirements that an applicant must meet to receive a 

BEACH Act implementation grant. It identifies relevant sections of the BEACH Act, 

briefly describes the corresponding performance criteria that EPA has developed, and 

provides additional grant-related information.

• Chapter 3 introduces a tiered, risk-based evaluation process that EPA recommends for 

states and tribes to classify and prioritize their recreational beaches. This step-by-step 

approach allows states to assess the relative human health risks and usage of their 

beaches and to assign an appropriate management ranking to each beach.

• Chapter 4 discusses the performance criteria related to monitoring and assessment and 

provides detailed technical guidance. This chapter provides a step-by-step approach for 

developing a conceptual monitoring framework and applying it to ranked beaches. It also 

includes performance requirements related to recreational water quality criteria and beach 

notification thresholds. 

• Chapter 5 describes the performance criteria and technical guidance related to a beach 

program’s public notification and risk communication. The chapter completes the 

conceptual framework by describing a tiered approach to notification. 

1.2 Pathogens

Microorganisms that have the potential to cause disease in a host are called pathogens. The small 

subset of infectious microorganisms that are capable of causing human diseases are known as 

human pathogens. 

Diseases from pathogens occur in a three-stage process: exposure, infection, and illness. 

Exposure to pathogens (e.g., in recreational water) might occur by direct contact, ingestion, 

inhalation, or entry into the body through an open wound. Infection occurs in a dynamic 

interaction involving the susceptibility of the host and the virulence of the pathogen. Illnesses 

that result from these various exposures and host-pathogen interactions can vary in their 

symptoms and severity. Commonly documented diseases from swimming in contaminated 

recreational waters include gastrointestinal illness; respiratory illnesses; skin rashes; and ear, eye, 

and wound infections. Sometimes these infections can result in death. 

July 31, 2014 6 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

Human pathogens in recreational waters can be naturally occurring or of environmental origin, 

such as the bacterium Vibrio vulnificus and the amoeba Naegleria fowleri, or they can be 

introduced through contamination events with the feces of humans and other warm-blooded 

animals (e.g., norovirus, enterohemorrhagic Escherichia coli, and Cryptosporidium sp.). Modern 

wastewater treatment is designed to be effective at killing bacteria, such as those that cause 

cholera and typhus, but is less effective at reducing human infective enteric viruses and protozoa. 

In waters that contain human fecal contamination, potentially all the waterborne diseases spread 

by the fecal-oral route could be contracted by bathers. In recreational waters, three groups of 

pathogens—viruses, bacteria, and parasitic protozoa—are of concern.

• Viruses are a group of infectious agents that require a host to replicate. The most 

significant virus group affecting water quality and human health grows and reproduces in 

the gastrointestinal tract of people and animals and therefore is called enteric viruses. 

Enteric viruses are excreted in feces, and they can include hepatitis A, rotaviruses, 

caliciviruses, noroviruses, adenoviruses, enteroviruses, and retroviruses. Most 

gastrointestinal illness associated with swimming in water contaminated with wastewater 

effluent and other human fecal sources can be attributed to human enteric viruses (Soller 

et al. 2010). Typical wastewater treatment practices reduce the concentration of 

pathogenic viruses by 10- to 100-fold (Flannery et al. 2012; Lodder and de Roda Husman 

2005), with secondary treated and disinfected effluent still containing human infective

doses of enteric virus. Viruses are species-specific to their host; that is, human pathogenic 

viruses can cause disease in humans but not in other organisms. 

• Bacteria are unicellular microorganisms that lack an organized nucleus and other 

membrane-bound organelles. Feces from humans and other warm-blooded animals contain 

large numbers of bacteria, including pathogenic species (such as Campylobacter spp. and 

Salmonella spp.). Some pathogenic bacterial species can be free-living and native to water 

environments, such as Vibrio cholera and Vibrio vulnificus. The pathogenic bacteria that 

are largely of concern for recreational waters are introduced into waters by fecal 

contamination (e.g., Campylobacter jejuni, Salmonella spp., pathogenic E. coli, Shigella).

• Protozoans are unicellular organisms with a defined nucleus. Pathogenic protozoans can 

be found in the feces of humans and other warm-blooded animals or can be part of the 

natural microflora found in the environment. Some species can exist in the environment 

as spores or cysts that hatch, grow, and multiply after ingestion, causing associated 

illness. Other species, such as Naegleria fowleri and schistosomes, cause disease in a 

free-living life stage (AWWA 2006). Two protozoan species of major concern as 

waterborne pathogens are Giardia lamblia and Cryptosporidium parvum (Academic 

Press 2003). 

Waters contaminated by nonhuman fecal material can also pose a risk to swimmers because 

some pathogens that infect animals can also cause illness in humans. These types of pathogens 

are called zoonotic pathogens. EPA conducted a review of the scientific literature on zoonotic 

pathogens during the development of the 2012 RWQC and found information on key waterborne 

zoonotic pathogens and their potential survivability in the environment (USEPA 2009c). A 

World Health Organization (WHO) and EPA joint publication (WHO 2004) provides further 

detailed information on zoonotic pathogens, including their geographic prevalence, potential 

disease prevention measures, good management practices for animal waste disposal, and an 

international perspective. Table 1-1 lists some of the diseases that can result from contact with 

July 31, 2014 7 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

water contaminated by human or animal waste, or naturally occurring bacterial, viral, and 

protozoan pathogens. 

1.3 Fecal Indicators

A variety of pathogens can be present in waters contaminated by fecal pollution. The types and 

numbers of pathogens present will be determined by the source and magnitude of the fecal 

contamination reaching a water body. Because of the great diversity of pathogens that can affect 

human health (see table 1-1), and the fact that pathogens are often seasonally and geographically 

distributed, widespread monitoring of recreational waters directly for all disease-causing 

microorganisms from fecal contamination is infeasible. Therefore, protection of public health for 

those using recreational waters has been accomplished for more than a century through the use of 

FIB such as E. coli and Enterococcus sp. FIB are bacterial groups or species that are naturally 

found in the guts of warm-blooded animals (including humans) and therefore are excreted in 

high densities in the feces of such animals (NRC 2004). They provide an estimation of the 

amount of feces (or degree of contamination) and, indirectly, the presence and quantity of fecal 

pathogens in the water3 (NRC 2004). Even though public health agencies have long used them to 

identify the potential for illness resulting from exposure to contaminated waters, numerous 

epidemiology studies have recently corroborated the use of FIB as predictors of adverse health 

outcomes (Colford et al. 2012; Pruss 1998; Wade et al. 2003; Wade et al. 2008; Wiedenmann et 

al. 2006; Zmirou et al. 2003). 

Since the middle of the last century, EPA and its federal predecessors have recommended levels 

of various FIB groups for the protection of the health of those recreating in surface waters 

(USEPA 1976, 1986, 2012a). For more information on indicators of fecal contamination, refer to 

EPA’s literature review of fecal indicator organisms in ambient waters (USEPA 2009a) and a 

scientific review of alternative indicators of fecal pollution (Savichtcheva and Okabe 2006). 

EPA recommends that states use two different types of FIB to monitor ambient waters, 

culturable E. coli and Enterococcus sp. Indicators of fecal contamination are not limited to the 

FIB EPA recommends and might include other types of microorganisms, such as viruses 

(e.g., coliphage), bacteria (e.g., Bacteroidales), and other enumeration methods for traditional 

FIB (e.g., immunomagnetic separation/adenosine triphosphate [IMS/ATP], qPCR). Risk 

managers might wish to choose indicators that perform effectively given local climatological and 

hydrological conditions (e.g., Clostridium perfringens in tropical waters) or possess 

characteristics that help to identify specific fecal contamination sources (e.g., sterols, brighteners, 

microbial genetic markers). Whichever indicators are used for beach notification programs, they 

must be reliable predictors of an exceedance or the likelihood of an exceedance of the applicable 

WQS. 

3 This technical concept was captured and codified into 33 U.S.C. 1362(23) by the BEACH Act amendment to the 

CWA. The BEACH Act defines a substance that indicates the potential for human infectious disease to be a 

pathogen indicator. Although FIB are not direct indicators of the presence or number of pathogens, their presence 

have been shown in epidemiology studies to be predictive of the potential for human infectious disease 

(e.g., gastrointestinal illness).

July 31, 2014 8 

 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

Table 1-1. Examples of waterborne pathogens in the three groups: 

bacteria, viruses, and protozoans

Pathogen Disease Symptoms and Effects

Bacteria Aeromonas spp. Wound infections, 

gastroenteritis

Fever, chills, nausea, abdominal pain, 

cellulites

Campylobacter spp. Gastrointestinal illness Diarrhea, abdominal pain, gastroenteritis

Clostridium spp. Gastrointestinal illness Diarrhea, fever, nausea, gastroenteritis

Escherichia coli* Gastrointestinal illness Vomiting, diarrhea, gastroenteritis

Helicobacter pylori Gastritis Diarrhea; peptic ulcers are a long-term 

sequela

Legionella pneumophila Legionellosis Acute respiratory illness

Leptospira spp. Leptospirosis Jaundice, fever (Weil’s disease)

Pseudomonas 

aeruginosa

Urinary tract infection, 

respiratory illness, wound 

infection

Dermatitis, soft tissue infections, 

bacteremia

Salmonella typhi Typhoid fever High fever, diarrhea, ulceration of the 

small intestine

Salmonella enterica Salmonellosis Diarrhea, dehydration

Shigella sonnei Shigellosis Bacillary dysentery

Vibrio vulnificus Vibriosis Wound infection, septicemia, diarrhea

Vibrio cholerae Cholera Extremely heavy diarrhea, dehydration

Yersinia enterolitica Yersinosis Diarrhea

Protozoa Balantidium coli Balantidiasis Diarrhea, dysentery

Cryptosporidium spp. Cryptosporidiosis Diarrhea

Entamoeba histolytica Amoebiasis (amoebic 

dysentery)

Prolonged diarrhea with bleeding, 

abscesses of the liver and small intestine

Giardia lamblia Giardiasis Mild to severe diarrhea, nausea, 

indigestion

Naegleria fowleri Amoebic 

meningoencephalitis

Fatal disease; inflammation of the brain

Viruses Adenoviruses Gastrointestinal illness, 

respiratory disease 

Gastroenteritis; vomiting; upper 

respiratory tract symptoms such as 

coughing, sore throat, fever

Astrovirus Gastrointestinal illness Gastroenteritis, vomiting, diarrhea

Enterovirus (including 

echovirus and Coxsackie 

virus)

Gastrointestinal illness, 

upper respiratory tract 

infection, myocarditis

Diarrhea, gastroenteritis, vomiting, fever, 

heart inflammation, cough, sore throat, 

bronchitis

Hepatitis A and E Infectious hepatitis Jaundice, fever

Norovirus Gastrointestinal illness Gastroenteritis, vomiting, diarrhea

Rotavirus Gastrointestinal illness Gastroenteritis, vomiting, diarrhea

*Denotes pathogenic E. coli, which differs from the nonpathogenic E. coli used as an FIB.

Sources: Cloete et al. 2004; Guillot and Loret 2010; USEPA 2002, 2009b; and WHO 2004.

July 31, 2014 9 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

It is important to note that FIB are not exclusively of fecal origin, and they can be part of the 

natural microflora in the environment. FIB have also been shown to persist and even grow in 

sand, sediments, and soils; on plant surfaces; and within algal mats and biofilms (Byappanahalli 

and Ishii 2010; Byappanahalli et al. 2012; Verhougstraete et al. 2010). FIB from these nonfecal 

sources have not been demonstrated to be related to the potential for human illness. EPA 

recommends that beach managers understand the potential fecal sources in the watershed 

affecting their beach to most effectively protect the health of beachgoers. Performing a sanitary 

survey4 (section 3.4.1) of the beach watershed is a good step toward this goal, and EPA has made 

available surveys for both marine and freshwater beaches.

1.4 Health Concerns

The primary route of exposure to enteric pathogens in recreational waters contaminated with 

feces is incidental or accidental ingestion of contaminated water. Swimming in contaminated 

waters results in an elevated potential of contracting gastrointestinal illness. Symptoms include 

chills, nausea, diarrhea, and fever and can vary in severity depending on the etiologic agent. 

Other health endpoints, such as respiratory illness, ear and eye infections, and skin rashes, have 

been observed from similar exposures, but gastrointestinal illness has been the disease observed 

most frequently. Pathogens from nonfecal sources can have various routes of exposure resulting 

in diseases affecting the eye, ear, skin, and upper respiratory tract. Infection can result when 

pathogenic microorganisms come into contact with small breaks and tears in the skin or ruptures 

in delicate membranes in the ear or nose.

People who acquire an illness from swimming in contaminated water do not always associate 

their illness with swimming because of the delay in the onset of the illness. For example, viral 

gastrointestinal illness is often mild, short-lived, and self-limiting, but symptoms usually take up 

to 24 hours to appear. Outbreaks of disease are documented when many people seek medical 

assistance because of a similar illness or the severity of the illness. However, people with mild 

illness often do not seek medical assistance. Therefore, disease outbreaks are often inconsistently 

recognized and the outbreak information in the literature is likely underestimated.

Pathogens can be difficult to routinely monitor in ambient waters because they often occur at 

levels below the detection limit, can require samples of large volumes of water, and often require 

concentration before enumeration (Borchardt and Spencer 2002; Girones et al. 2010; Rochelle 

and Schwab 2006). In addition, spatial and temporal variability in the occurrence and level of 

pathogens should be considered in any ambient pathogen-monitoring regime. As discussed in 

section 1.3, public health agencies have traditionally relied on FIB to measure the magnitude of 

fecal contamination in a water body. Since the 1950s, studies have been conducted to gauge how 

the level of fecal contamination translates into potential human health risks through FIB

measurements. Many of these studies, called epidemiology studies, have established a link 

between the FIB level in bathing waters and the incidence of swimming-associated disease 

symptoms. EPA conducted a review of the epidemiology studies found in the scientific literature 

during the development of the 2012 RWQC (USEPA 2009b). For many of the epidemiology 

studies, the pathogens causing many of the reported illnesses were likely viral in nature 

(e.g., norovirus) (Cabelli 1983; Soller et al. 2010). Additional analyses of the existing 

4 http://www2.epa.gov/beach-tech/beach-sanitary-surveys

July 31, 2014 10 

 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

epidemiological data have shown that the presence of enteroviruses was strongly associated with 

the reported gastrointestinal illness (Wade et al. 2003). Viruses have characteristics, such as their 

susceptibility to treatment in a wastewater treatment plant and fate and transport behavior in the 

environment, that differ from those of the bacteria used as fecal indicators.

In 1972 EPA began to study the relationship between the quality of bathing water and the 

resulting health effects. Studies in the 1970s and 1980s examined the differences in symptomatic 

illness between swimming and non-swimming beachgoers at marine and freshwater bathing 

beaches affected by treated and nontreated human fecal contamination (Cabelli 1983; Dufour 

1984). The studies found that swimmers who recreate in water contaminated with sewage are at 

greater risk of contracting gastrointestinal illness than non-swimmers, and that the reported 

swimming-associated illness rate increases as the quality of the bathing water (as measured by 

FIB) degrades. 

A newer study has shown that even at frequently monitored beaches with very low 

concentrations of fecal indicators, there is a risk of contracting a swimming-related illness. 

Starting in 2003 and continuing through 2010, EPA conducted several epidemiological 

investigations as part of the National Epidemiologic and Environmental Assessment of 

Recreational Water (NEEAR) study program at freshwater and marine beaches affected 

predominantly by secondary treated and disinfected sewage effluent. The purpose of the NEEAR 

study program was to determine the relationship between health effects in swimmers and water 

quality measured using a quantitative polymerase chain reaction (qPCR) analytical methodology 

that produces quantitative results in two to three hours (Wade et al. 2008). Chapter 4 contains 

more information on the qPCR methodology. 

The NEEAR results found increases in gastrointestinal illness with increasing FIB levels as 

measured through the use of the qPCR analytical methodology as specifically applied to 

enumeration of Enterococcus sp. (Wade et al. 2006, 2010). A stronger association was found 

with gastrointestinal illness than with other health endpoints (i.e., rash, upper respiratory illness, 

eye ailment, earache, and infected cut). The NEEAR epidemiological studies found the 

occurrence of gastrointestinal illness to be positively associated with levels of Enterococcus spp. 

as enumerated with EPA’s Enterococcus spp. qPCR Method 1611 in marine and fresh waters 

and with Bacteroidales enumerated with EPA’s Bacteroidales qPCR method in marine waters 

(Wade et al. 2008, 2010). The association between gastrointestinal illness and enterococci 

enumerated by membrane filtration (EPA Method 1600) in the NEEAR study was positive but 

was not statistically significant across the range of water quality observed. However, there was a 

similar significant increase of illness noted at 30 and 35 colony-forming units (CFU) enterococci 

per 100 milliliters (mL). The results of the NEEAR studies substantially informed the 2012 

RWQC. 

1.5 Water Quality Criteria and Standards for Bacteria

1.5.1 State Implementation of the 2012 Recreational Water Quality Criteria (RWQC)

WQS are provisions of state, tribal, or federal law consisting of a designated use or uses for the 

waters of the United States and water quality criteria based upon such use (40 CFR 131.3(i)). 

July 31, 2014 11 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

They are the foundation of the nation’s water quality management program and define the water 

quality goals for a water body. 

Section 304(a)(1) of the CWA directs EPA to publish recommended water quality criteria 

accurately reflecting the latest scientific knowledge on the effects of the presence of pollutants in 

water on health and welfare, including recreation. The criteria EPA published under section 

304(a) are intended to provide guidance to states in establishing water quality criteria in their 

WQS. Section 304(a)(9) of the CWA, as amended by the BEACH Act, directs EPA to publish 

new or revised water quality criteria recommendations for pathogens and pathogen indicators 

(including a revised list of testing methods, as appropriate) on the basis of the results of studies 

EPA conducted under section 104(v) of the CWA, for the purpose of protecting human health in 

coastal recreation waters. EPA’s 2012 Recreational Water Quality Criteria (USEPA 2012b) 

meet the requirements of section 304(a)(9), but also include section 304(a) recommendations for 

noncoastal recreation waters because EPA developed the 2012 RWQC to protect all waters in the 

United States designated for primary contact recreation.

CWA section 303(i)(1)(B) directs BEACH Act coastal and Great Lakes states and tribes with

coastal recreation waters designated for primary contact use for which EPA has approved WQS

under the CWA to submit new or revised WQS for BEACH Act waters to EPA for review by 

December 2015 (i.e., “36 months after the date of publication” of the 2012 RWQC). EPA also 

encourages states and tribes with non-BEACH Act waters to review and revise their WQS as 

appropriate during their next triennial reviews.

Revised WQS from any state or tribe must include criteria that are scientifically defensible and 

protective of the primary contact recreation use. In the 2012 RWQC, EPA recommends that the 

state or tribal RWQC consist of a magnitude (the maximum amount of a pollutant that may be 

present in a water body that supports the designated use) expressed as a geometric mean (GM)

and statistical threshold value (STV); a duration (the period of time over which the magnitude is 

calculated); and frequency of exceedance (the maximum number of times the pollutant may be 

present above the magnitude over the specified duration). If a state or tribe were to adopt criteria 

based on the 2012 RWQC recommendations, they would be considered scientifically defensible 

and protective of the primary contact recreation use.

EPA regulations at 40 CFR part 131 provide that in establishing numeric criteria, states should 

establish criteria values based on EPA’s section 304(a) recommendations (e.g., the 2012 

RWQC), or section 304(a) guidance modified to reflect site-specific conditions, or adopt criteria 

based on other scientifically defensible methods (40 CFR 131.11(b)(1)). EPA reviews and 

approves state WQS. 

The 2012 RWQC, like the 1986 criteria, recommend using culturable E. coli and enterococci as 

indicators of fecal contamination for fresh water and enterococci for marine water. However, 

there are several differences between the current and previous criteria recommendations. The 

2012 RWQC differ as follows. They: 

• Offer similar public health protection for fresh and marine waters. 

• Provide two sets of recommended criteria values that protect the designated use of 

primary contact recreation. 

July 31, 2014 12 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

• Include a new statistical value, the STV, to be used in conjunction with the recommended 

GM value to evaluate the long-term health of a water body. 

• Consist of a magnitude, duration, and frequency for both the GM and the STV. 

The 1986 Bacteria Criteria document included four single sample maximum (SSM) values for 

different levels of beach usage (use intensities). In the 2012 RWQC, EPA removed those 

recommendations and instead provided states and tribes with options for selecting a beach 

notification threshold not adopted into WQS. The options differ, depending on whether the state 

or tribe receives a grant under CWA section 406. 

States and tribes receiving grants under CWA section 406(b) must agree to take a notification 

action on an exceedance or likely exceedance of the applicable WQS as a condition of receiving 

a grant. The FY 2014 beach grant workplans must include a commitment to develop a schedule 

to adopt new or revised WQS pursuant to CWA section 303(i)(1)(B) by FY 2016 and a schedule 

to identify and use an appropriate beach notification threshold by FY 2016. EPA expects that 

states and tribes receiving beach grants under CWA section 406 will select as their beach 

notification threshold the Beach Action Value (BAV) based on the 75th percentile value that 

corresponds to the indicator and illness rate in their adopted WQS. However, they do have the 

option to submit a written justification to use a different value. The alternative value should be 

selected from the same statistical distribution as the illness rate and corresponding values 

adopted into state WQS, and the justification should explain why this value is preferable to the 

EPA-preferred 75th percentile value.

Other states and tribes have additional options, as discussed in sections 4.7.2.1 and 4.7.3. 

The 2012 RWQC also make available information regarding a qPCR enumeration method 

(Method 1611) for the more rapid detection of Enterococcus spp. in marine and fresh water 

compared to the traditional culturable enumeration methods. Method 1611 and an improved 

Method 1609 are anticipated to provide increased public health protection by facilitating timely 

notification to swimmers of elevated FIB levels. 

Section 4.7 discusses the beach program within the context of the 2012 RWQC

recommendations, options for selecting a beach notification threshold, and other elements.

1.5.2 Implementation Guidance 

It is beyond the scope of this document to provide an in-depth discussion of WQS and associated 

technical issues. However, EPA has developed some technical support materials as guidance to 

states on how to implement the 2012 Recreational Water Quality Criteria (USEPA 2012b) and 

plans to develop more in the near future.

EPA strongly encourages states and tribes to review the technical support materials because they 

provide guidance on how to implement tools that states and tribes can use (1) to enhance public 

health protection when implementing state and tribal WQS for primary contact recreation and 

(2) to develop WQS that differ from EPA’s recommended criteria (i.e., alternative criteria). 

These tools include sanitary surveys; predictive models; epidemiological studies; quantitative 

microbial risk assessment (QMRA); analytical methods, including Enterococcus spp. qPCR 

July 31, 2014 13 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

(Method 1611; USEPA 2012a); and approaches for developing criteria using alternative fecal 

indicators and methods. The technical support materials are available at 

http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/index.cfm. 

Method 1611 can be found at http://water.epa.gov/scitech/methods/cwa/bioindicators/index.cfm. 

1.6 Chapter 1 References

Academic Press. 2003. Handbook of Water and Wastewater Microbiology. Chapter 40, p. 695. 

Elsevier, San Diego, CA. 

AWWA (American Water Works Association). 2006. Waterborne pathogens: Manual of Water 

Supply Practices. M48. American Water Works Association, Washington, DC. 

Borchardt, M.A., and S.K. Spencer. 2002. Concentration of Cryptosporidium, microsporidia and 

other water-borne pathogens by continuous separation channel centrifugation. Journal of 

Applied Microbiology 92: 649–656. 

Byappanahalli, M.N., and S. Ishii. 2010. Environmental Sources of Fecal Bacteria. In The Fecal 

Bacteria, ed. M.J. Sadowsky and R.L. Whitman, pp. 93–110. ASM Press, Washington, 

DC.

Byappanahalli, M.N., B.M. Roll, and R.S. Fujioka. 2012. Evidence for occurrence, persistence, 

and growth potential of Escherichia coli and enterococci in Hawaii's soil environments. 

Microbes and Environments 27(2): 164–170. 

Cabelli, V. 1983. Health Effects Criteria for Marine Recreational Waters. EPA-600/1-80-031. 

U.S. Environmental Protection Agency, Cincinnati, OH. 

Cloete, E., J. Rose, L.H. Nel, and T. Ford. 2004. Microbial Waterborne Pathogens. IWA 

Publishing, London, UK. 

Colford, J.M., K.C. Schiff, J.F. Griffith, V. Yau, B.F. Arnold, C.C. Wright, J.S. Gruber, T.J. 

Wade, S. Burns, J. Hayes, C. McGee, M. Gold, Y. Cao, R.T. Noble, R. Haugland, and 

S.B. Weisberg. 2012. Using rapid indicators for Enterococcus to assess the risk of illness 

after exposure to urban runoff contaminated marine water. Water Research 46(7): 2176–

2186. 

Dufour, A. 1984. Health Effects Criteria for Fresh Recreational Waters. EPA-600-1-84-004. 

U.S. Environmental Protection Agency, Cincinnati, OH. 

Flannery, J., S. Keaveney, P. Rajko-Nenow, V. O’Flaherty, and W. Dore. 2012. Concentration of 

norovirus during wastewater treatment and its impact on oyster contamination. Applied 

and Environmental Microbiology 79(13): 3400–3406. 

Girones, R, M. A. Ferrus, J. I. Alonso, J. Rodriguez-Manzano, B. Calgua, A. de Abreu Correa, 

A. Hundesa, A. Carratala, and S. Bofil-Mas. 2010. Molecular detection of pathogens in 

water—the pros and cons of molecular techniques. Water Research 44: 4325–4339. 

July 31, 2014 14 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

Guillot, E., and J. Loret. 2010. Waterborne Pathogens: Review for the Drinking Water Industry. 

IWA Publishing, London, UK. 

Lodder, W.J., and A.M. de Roda Husman. 2005. Presence of norovirus and other enteric viruses 

in sewage and surface waters in Netherlands. Applied Environmental Microbiology 71(3): 

1453–1461. 

NRC (National Research Council). 2004. Indicators for Waterborne Pathogens. The National 

Academies Press, Washington, DC. 

Pruss, A. 1998. Review of epidemiological studies on health effects from exposure to 

recreational water. International Journal of Epidemiology 27: 1–9. 

Rochelle, P. A., and K. J. Schwab. 2006. Molecular Detection of Waterborne Microorganisms. 

Chapter 4 in Waterborne Pathogens: Manual of Water Supply Practices. 2nd ed. 

American Water Works Association, Washington, DC. 

Savichtcheva, O., and S. Okabe. 2006. Alternative indicators of fecal pollution: Relations with 

pathogens and conventional indicators, current methodologies for direct pathogen 

monitoring and future application perspectives. Water Resources 40: 2463–2476. 

Soller, J.A., T. Bartrand, N.J. Ashbolt, J. Ravenscroft, and T.J. Wade. 2010. Estimating the 

primary etiologic agents in recreational freshwaters impacted by human sources of fecal

contamination. Water Resources 44: 4736–4747. 

USEPA (U.S. Environmental Protection Agency). 1976. Quality Criteria for Water 1976 (The 

Red Book). EPA 440/9-76-023. U.S. Environmental Protection Agency, Washington, 

DC.

———. 1986. EPA’s Ambient Water Quality Criteria for Bacteria—1986. EPA 440/5-84-002. 

U.S. Environmental Protection Agency, Washington, DC. 

———. 2002. National Beach Guidance and Required Performance Criteria for Grants. EPA823-B-02-004. U.S. Environmental Protection Agency, Office of Water, Washington, 

DC.

———. 2008. Great Lakes Beach Sanitary Survey User Manual. EPA-823-B-06-001. U.S. 

Environmental Protection Agency, Office of Water, Washington, DC. 

———. 2009a. Fecal Indicator Organism Behavior in Ambient Waters and Alternative 

Indicators for Tropical Regions, U.S. Environmental Protection Agency, Office of 

Science and Technology, Washington, DC. 

———. 2009b. Review of Published Studies to Characterize Relative Risks from Different 

Sources of Fecal Contamination in Recreational Water. EPA 822-R-09-001. U.S. 

Environmental Protection Agency, Office of Science and Technology, Washington, DC. 

July 31, 2014 15 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

———. 2009c. Review of Zoonotic Pathogens in Ambient Waters. EPA822-R-09-002. 

U.S. Environmental Protection Agency, Washington, DC. 

http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/2009_

07_16_criteria_recreation_zoonoticpathogensreview.pdf. 

———. 2012a. Method 1611: Enterococci in Water by TaqMan® Quantitative Polymerase 

Chain Reaction (qPCR) Assay. EPA-821-R-12-008. U.S. Environmental Protection 

Agency, Office of Science and Technology, Washington, DC. 

———. 2012b. Recreational Water Quality Criteria. EPA 820-F-12-058. U.S. Environmental 

Protection Agency, Office of Water, Washington, DC. 

———. 2013. Marine Beach Sanitary Survey User Manual. U.S. Environmental Protection 

Agency, Office of Science and Technology, Washington, DC. 

Verhougstraete, M.P., M.N. Byappanahalli, J.B. Rose, and R.L. Whitman. 2010. Cladophora in 

the Great Lakes: Impacts on beach water quality and human health. Water Science and 

Technology 62(1):68–76. 

Wade, T.J., N. Pai, J. N.S. Eisenberg, and J.M. Colford, Jr. 2003. Do U.S. Environmental 

Protection Agency water quality guidelines for recreational waters prevent 

gastrointestinal illness? A systematic review and meta-analysis. Environmental Health 

Perspectives 111(8): 1102–1109. 

Wade, T.J., R.L. Calderon, E. Sams, M. Beach, K.P. Brenner, A.H. Williams, and A.P. Dufour. 

2006. Rapidly measured indicators of recreational water quality are predictive of 

swimming-associated gastrointestinal illness. Environmental Health Perspectives 114(1): 

24–28. 

Wade, T.J., R.L. Calderon, K.P. Brenner, E. Sams, M. Beach, R. Haugland, L. Wymer, and A.P. 

Dufour. 2008. High sensitivity of children to swimming-associated gastrointestinal 

illness—Results using a rapid assay of recreational water quality. Epidemiology 19(3):

375–383. 

Wade, T.J., E. Sams, K.P. Brenner, R. Haugland, E. Chern, M. Beach, L. Wymer, CC. Rankin, 

D. Love, Q. Li, R. Noble, and A.P. Dufour. 2010. Rapidly measured indicators or 

recreational water quality and swimming-associated illness at marine beaches: A 

prospective cohort study. Environmental Health 9:66. 

WHO (World Health Organization). 2004. Waterborne zoonoses: identification, causes and 

control, ed. J.A. Cotruvo, A. Dufour, G. Rees, J. Bartram, and R. Carr. IWA Publishing, 

London, UK. 

Wiedenmann, A., P. Krüger, K. Dietz, and J.M. López-Pila. 2006. A randomized controlled trial 

assessing infectious disease risks from bathing in fresh recreational waters in relation to 

the concentration of Escherichia coli, intestinal enterococci, Clostridium perfringens, and 

somatic coliphages. Environmental Health Perspectives 114(20): 228–236. 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 1

Zmirou, D., L. Pena, M. Ledran, and A. Letertre. 2003. Risks associated with the microbiological 

quality of bodies of fresh and marine water used for recreational purposes: Summary 

estimates based on published epidemiological studies. Archives of Environmental Health

2003(58): 703–711. 

July 31, 2014 17 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 2 

Chapter 2: Grants and Required Performance Criteria

This chapter addresses the basic requirements that an applicant must meet to receive a BEACH 

Act program implementation grant. It identifies relevant sections of the BEACH Act, briefly 

describes the corresponding performance criteria that EPA developed, and provides additional 

grant-related information. Beginning with FY 2014 beach grants that are awarded after this 

document is final, states5 and tribes must meet the performance criteria in this document to 

receive a grant under section 406(b). However, this document contains a wealth of information 

and many best management practices that states and tribes might want to follow. The general 

approach and principles would also be applicable to inland beaches, although some 

modifications might be necessary.

Key changes to chapter 2 from the 2002 guidance document

• Reorganizes the 9 performance criteria and renumbers them to 11.

• Introduces new requirements for performance criteria 2, 3, 4, and 6.

• Introduces new performance criterion 10.

2.1 BEACH Act Conditions and Requirements Applicable to 

Section 406 Grants

EPA’s statutory authority to award grants under section 406(b) of the BEACH Act includes a 

series of conditions and requirements for developing and implementing a beach monitoring and 

notification program funded by the grant. Section 406(c) of the CWA, which includes grant 

conditions that address the content of state and tribal programs, applies to all grants awarded to

states and tribes under the authority of section 406, regardless of whether the grant is for 

development or implementation of a beach monitoring program. Section 406(b)(3)(A), which 

addresses reporting, applies to all development and implementation grants awarded to states and 

tribes under the authority of section 406. Section 406(b)(3)(B), which addresses delegation to 

local governments, applies to development and implementation grants awarded to states only 

(not territories or tribes). The requirements set forth in section 406(b)(2)(A) apply to all

implementation grants. 

2.2 Performance Criteria

EPA has 11 performance criteria for implementing monitoring, assessment, and notification 

programs based on the requirements in CWA section 406. To be eligible for a grant to implement 

a monitoring and notification program, the state’s or tribe’s program must be consistent with the

applicable performance criteria. FY 2014 beach grants awarded before this document is final 

must be consistent with the performance criteria in the 2002 National Beach Guidance and 

Required Performance Criteria for Grants. Beach grants for FY 2014 and beyond that are 

awarded after this document is final must be consistent with the performance criteria in this 

5 For simplicity, throughout the remainder of this document, unless otherwise noted, we use the general term state to 

refer to the grant recipients discussed above (i.e., eligible states, territories, or local governments). 

July 31, 2014 18 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 2 

document. The performance criteria also apply to federal agency programs and programs that 

EPA implements directly. Table 2-1 lists general requirements of the performance criteria, crossreferenced to the chapters in which they are discussed. They are also summarized in sections 

2.2.1 through 2.2.11. Subsequent chapters provide the specific requirements associated with each 

performance criterion, along with more detailed discussions. 

Table 2-1. Summary of BEACH Act performance criteria

Category

Performance 

criterion General requirement

Chapter 

where 

discussed

Evaluation and 

Classification 1 Risk-based beach evaluation and classification process 3 

Monitoring

2 Tiered monitoring plan 4

3 Methods and assessment procedures 4

4 Monitoring report submission 4

5 Delegation of monitoring responsibilities 4

Public Notification 

and Prompt Risk 

Communication

6 Public notification and risk communication plan 5

7 Actions to notify the public 5

8 Notification report submission 5

9 Delegation of notification responsibilities 5

Implementation 

Schedules 10 Adoption of new or revised WQS and identification and use of a beach notification threshold 4 

Public Evaluation 11 Public evaluation of program 2

2.2.1 Risk-based Beach Evaluation and Classification Process (Performance 

Criterion 1)

Performance criterion 1 requires a state or tribe to develop a risk-based beach evaluation and 

classification process and apply the process to its coastal recreation waters. The process must 

describe the factors used in the state’s or tribe’s evaluation and classification process and explain 

how the state’s or tribe’s coastal recreation waters are ranked as a result of the process. That 

process must result in a list of specific coastal recreation waters adjacent to beaches or similar 

points of access used by the public. Chapter 3 discusses general and specific requirements for 

this performance criterion in more detail.

2.2.2 Tiered Monitoring Plan (Performance Criterion 2)

Performance criterion 2 requires a state or tribe to develop a tiered monitoring plan. The plan 

must adequately address the frequency and location of monitoring and the assessment of coastal 

recreation waters on the basis of the periods of recreational use of the waters, the nature and 

extent of use during certain periods, the proximity of the waters to known point and nonpoint 

sources of pollution, and any effect of storm events on the waters. EPA has added three new 

considerations to the basis for developing the tiered monitoring plan. Chapter 4 discusses general 

and specific requirements for this criterion in more detail.

July 31, 2014 19 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 2 

2.2.3 Methods and Assessment Procedures (Performance Criterion 3)

Performance criterion 3 requires a state or tribe to develop detailed assessment methods and 

procedures. States and tribes must adequately address and submit to EPA methods for detecting 

levels of pathogens and pathogen indicators that are harmful to human health in coastal 

recreation areas. States and tribes must also provide documentation to support the validity of 

methods other than those that EPA validated or approved. Finally, states and tribes must identify 

and submit to EPA assessment procedures for identifying short-term increases in pathogens and 

pathogen indicators that are harmful to human health in coastal recreation areas. Chapter 4 

discusses general and specific requirements for this criterion in more detail. 

2.2.4 Monitoring Report Submission (Performance Criterion 4)

Performance criterion 4 requires states and tribes to develop a mechanism to collect and report 

monitoring data in timely reports. States and tribes must report their monitoring data to the 

public in a timely manner, including posting on a website. They must report their monitoring 

data to EPA at least annually or at a frequency required by the EPA Administrator. EPA 

encourages states to coordinate closely with local governments to ensure that monitoring 

information is submitted consistently. Reported data must be consistent with the list of required 

data elements (see http://water.epa.gov/grants_funding/beachgrants/datausers_index.cfm).

Chapter 4 discusses general and specific requirements for this criterion in more detail.

2.2.5 Delegation of Monitoring Responsibilities (Performance Criterion 5)

Performance criterion 5 requires a state to document any delegation of monitoring 

responsibilities that might have been made to local governments. If monitoring responsibilities 

are delegated to local governments, the state grant recipient must describe the process by which 

the state may delegate to local governments responsibility for implementing the monitoring 

program. Chapter 4 discusses general and specific requirements for this criterion in more detail.

2.2.6 Public Notification and Risk Communication Plan (Performance Criterion 6)

Performance criterion 6 requires that a state or tribe develop a public notification and risk 

communication plan. The plan must describe the state’s or tribe’s public notification efforts and 

measures to inform the public of the potential risks associated with water contact activities in the 

coastal recreation waters that do not meet applicable WQS. 

The state or tribe must adequately identify measures to promptly communicate the occurrence, 

nature, location, pollutants involved, and extent of any exceedance or likelihood of exceedance 

of applicable WQS for pathogens and pathogen indicators. The state or tribe must identify how it 

will promptly communicate that information to EPA. States are responsible for identifying how 

they will promptly communicate the failure to meet applicable standards to a designated official 

of the local government in the area adjoining the coastal recreation waters with water quality 

problems. 

A state or tribal government program must describe procedures for posting signs at beaches or 

similar points of access, or taking functionally equivalent communication measures that are 

sufficient to give notice to the public that the coastal recreation waters are not meeting or are not 

July 31, 2014 20 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 2 

expected to meet applicable WQS for pathogens and pathogen indicators. Chapter 5 discusses 

general and specific requirements for this criterion in more detail.

2.2.7 Actions to Notify the Public (Performance Criterion 7)

Performance criterion 7 requires that a state or tribe give notice to the public when coastal 

recreation waters are not meeting or are not expected to meet applicable WQS for pathogens and 

pathogen indicators. 

A state or tribe must post signs at beaches or similar points of access, or provide functionally 

equivalent communication measures that are sufficient to give notice to the public that the 

coastal recreation waters are not meeting or are not expected to meet applicable WQS for 

pathogens and pathogen indicators. Chapter 5 discusses general and specific requirements for 

this criterion in more detail.

2.2.8 Notification Report Submission (Performance Criterion 8)

Performance criterion 8 requires that states and tribes compile their notification data into timely 

reports. States and tribes must report to EPA the actions they have taken to notify the public 

when WQS are exceeded. Chapter 5 discusses general and specific requirements for this criterion 

in more detail.

2.2.9 Delegation of Notification Responsibilities (Performance Criterion 9)

Performance criterion 9 requires that states describe any notification responsibility they have 

delegated or intend to delegate to local governments. The state must describe the process by 

which the state may delegate to local governments responsibility for implementing the 

notification program. Chapter 5 discusses general and specific requirements for this criterion in 

more detail.

2.2.10 Adoption of New or Revised WQS and Identification and Use of a Beach 

Notification Threshold (Performance Criterion 10)

Performance criterion 10 is a new criterion, intended to focus on adoption of new or revised 

WQS as required by CWA section 303(i)(1)(B) and identification and use of an appropriate 

beach notification threshold. These requirements apply to states and tribes receiving grants under 

CWA section 406(b), and they will be implemented through conditions included in the grants. 

Chapter 4 discusses general and specific requirements for this criterion in more detail.

2.2.11 Public Evaluation of Program (Performance Criterion 11) 

Performance criterion 11 requires that states and tribes provide the public with an opportunity to 

review the program through public notice and provide an opportunity to comment. This is not a 

one-time requirement; public input must be sought whenever a state or tribe makes significant 

changes to its beach program. If a state or tribe significantly changes its List of Beaches, beach 

ranking, or other elements of its monitoring and notification program, the public must have an 

opportunity to review the changes before implementation. Further, states and tribes should 

July 31, 2014 21 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 2 

consult with the applicable EPA Region prior to making significant program changes. Table 2-2 

lists the general and specific requirements associated with this criterion.

The public evaluation can be accomplished through notice and public comment, meetings, 

forums, or workshops. For example, when classifying and ranking beaches, it is beneficial to 

gather input from members of the community regarding the recreational waters they would like 

monitored. Annual public or community meetings, surveys of the users at the beach, local 

newspaper articles, or other sources can provide insight into public opinion about the beach, 

including why the beach is or is not used (e.g., for sunning, running, swimming, or surfing); 

perceptions of water quality and health problems; and whether beach users desire a monitoring 

and notification program (if none exists) or how satisfied they are with the current program. 

Table 2-2. Summary of public evaluation of program performance criterion

Performance criteria Chapter 

General requirement Specific requirements section

Public Evaluation of Program 

(Performance Criterion 11): 

This performance criterion 

requires a state, tribe, territory, 

or local government to provide 

the public with an opportunity to 

review the program through 

public notice and an 

opportunity to comment.

• Provide an opportunity for the public to comment on the following

components of a beach monitoring and public notification

program:

o Beach evaluation and classification process, including a list

of waters to be monitored and beach ranking.

o Sampling design and monitoring plan, including sampling

location and sampling frequency.

o Public notification and risk communication plan, including

methods to notify the public of a swimming advisory.

3.6.2

4.3.3.5

5.2.4

2.3 Additional Grant Information

2.3.1 Grant Program Phases

The BEACH Act authorizes EPA to award grants for both developing and implementing 

monitoring and notification programs. Accordingly, EPA established a two-phase grant 

program—an initial program development phase followed by a program implementation phase. 

The initial phase of the grant program focuses on developing a state or tribal beach monitoring 

and notification program. Currently, only tribes receive development grants. The second phase of 

the grant program focuses on implementing a state or tribal beach monitoring and notification 

program. All coastal and Great Lakes states and territories are currently receiving 

implementation grants.

2.3.2 Eligibility for Grants

• State governments. Coastal and Great Lakes states are eligible to apply for grants to

develop and implement monitoring and notification programs for their coastal recreation

waters. In the BEACH Act, the term state applies to 30 coastal and Great Lakes states

and five coastal territories defined in CWA section 502—the Commonwealth of Puerto

Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the

Northern Mariana Islands.

July 31, 2014 22 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 2 

• Tribal governments. Section 518(e) of the CWA authorizes EPA to treat eligible Indian 

tribes in the same manner as states for the purpose of CWA section 406. To receive 

BEACH Act grant funds, a tribe must have coastal recreation waters designated for 

primary contact use for which EPA has approved WQS under the CWA. Currently, three 

tribes—the Grand Portage Band of Lake Superior Chippewa, the Makah Nation of 

Washington State, and the Bad River Band of the Lake Superior Tribe of Chippewa 

Indians—receive BEACH Act grants.

• Local governments. The BEACH Act authorizes EPA to make grants to local 

governments for developing and implementing monitoring and notification programs 

only if EPA determines that the state or tribe is not implementing a program that meets 

the requirements of the statute. Erie County, Pennsylvania, is the only local government 

currently receiving a BEACH Act grant.

As mentioned previously, for the remainder of this document the term state refers to states, 

territories, and local governments unless otherwise noted. 

2.3.3 Selection Process

The EPA Administrator has delegated the authority to award BEACH Act program development 

and implementation grants to the Assistant Administrator of the Office of Water (OW) and to 

EPA Regional Administrators. EPA regional offices award program development and 

implementation grants through a noncompetitive process. 

If funds are available, EPA expects to award grants to all eligible state, territorial, tribal, and 

local government applicants that meet the performance criteria specified in this document and 

other statutory and regulatory requirements pertaining to grants. 

2.3.4 Grant Award Process

EPA will award and administer BEACH Act grants according to the regulations at 40 CFR part 

31 (Uniform Administrative Requirements for Grants and Cooperative Agreements to State and 

Local Governments). EPA regional offices have the lead responsibility for providing grant 

application packages and advice after EPA makes funding available. For information on specific 

grants, grant coordinators, or other pertinent information, visit the Beaches website at 

http://www2.epa.gov/beaches. 

July 31, 2014 23 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

Chapter 3: Risk-based Beach Evaluation and Classification 

Process 

Protecting public health is the primary objective for a beach monitoring and notification 

program. To meet this objective, beach program managers should strive to “know your beach” 

and understand the potential for exposure to fecal contamination, and thus the adverse public 

health risk that might occur at their beaches.

Conducting a risk-based beach evaluation and classification process is required for BEACH Act 

grantees. EPA may award BEACH Act grants to implement a monitoring and notification 

program only if (1) the grant recipient prioritizes its grant funds for particular coastal recreation 

waters based on the use of the water and the risk to human health presented by pathogens and 

pathogen indicators and (2) the grant recipient makes available to EPA the factors used to 

prioritize the use of funding (see CWA sections 406(b)(2)(A) (ii) and (iii)). 

To meet this requirement, EPA recommends that states and tribes follow a stepwise approach to

conducting a beach evaluation and classification of their beaches. EPA’s recommended approach 

is discussed throughout this chapter and illustrated in figures 3-1 through 3-6. The term use, as 

employed in this context refers to the usage of beach waters by the public; for example, how 

many people use a beach and when do periods of peak usage occur. The term risk in this context 

refers to the susceptibility of beach waters to fecal contamination, particularly human, and 

therefore the increased risk of adverse public health effects due to pathogens. 

Chapters 3, 4, and 5 should be considered together. This chapter (chapter 3) explains how to 

classify and rank beaches using risk management decisions based on potential public health 

impact. Chapter 4 explains how to translate the beach rankings into detailed tiered monitoring 

plans. Chapter 5 discusses the linkage to a state or tribe’s notification and risk communication 

plans for beaches. 

Key changes to chapter 3 from the 2002 guidance document

• Expands and clarifies the process for characterizing beach risk and use (section 3.4). 

• Strengthens the link between prioritizing beaches and developing a tiered monitoring 

plan (sections 3.5 and 3.6). 

• Makes sanitary surveys a central part of the beach classification process (section 3.4). 

• Provides detailed guidance on developing the List of Beaches (section 3.6). 

July 31, 2014 24 

3.1 Performance Criterion

Performance criterion 1 (introduced in chapter 2) addresses the beach evaluation and 

classification process that states and tribes must conduct. Table 3-1 includes the general and 

specific requirements associated with this criterion, cross-referenced to the chapter sections. 

States and tribes may develop their own evaluation and classification approach, but they must 

address these requirements.
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

This approach might also be helpful for assessing beaches in programs not funded by section 

406(b) BEACH Act grants. (For example, these could include inland beaches in states that do not 

receive beach grants.) For such programs, the requirements described below should be 

interpreted as helpful recommendations, not binding requirements. 

Table 3-1. Summary of risk-based evaluation and classification process

performance criterion

Performance criteria Chapter 

General requirement Specific requirements section

Risk-based Beach Evaluation and 

Classification Process (Performance 

Criterion 1). The state or tribe must develop a 

risk-based beach evaluation and classification 

process and apply it to the state’s coastal 

recreation waters. A state or tribal program 

must describe the factors used in its 

evaluation and classification process and 

explain how its coastal recreation waters are 

ranked as a result. The process must result in 

a List of Beaches. 

• Identify factors used to evaluate and rank 

beaches.

• Identify state or tribal coastal recreation 

waters.

• Notify EPA at least annually if the List of 

Beaches changes significantly because of 

revised beach rankings or changes to 

monitoring and notification requirements and 

considerations.

• Provide for public review of the risk-based rank 

and classification.

3.2–3.6

2.2.10

EPA recommends using the following five steps in an evaluation and classification process to 

develop a statewide or tribal List of Beaches:

• Step 1: Identify coastal recreation waters.

• Step 2: Identify “BEACH Act” beaches.

• Step 3: Characterize the beach to determine risk and use.

• Step 4: Rank beaches by tiers.

• Step 5: Classify beaches into a List of Beaches, identifying program and non-program 

beaches.

Details on each step are provided below. 

3.2 Step 1: Identify Coastal Recreation Waters

The first step in the risk-based classification process (figure 3-1) has two parts: identifying 

coastal waters and identifying the designated use of the waters.

July 31, 2014 25 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

Figure 3-1. Step 1: Identify coastal recreation waters.

The BEACH Act defines coastal recreation waters as the Great Lakes and marine coastal waters 

(including coastal estuaries) designated under CWA section 303(c) by a state or tribe for 

swimming, bathing, surfing, or similar water contact activities.

Figure 3-2. Coastal and noncoastal waters.

3.2.1 Coastal Versus Noncoastal Waters

To identify coastal recreation waters, managers 

should first determine which of their waters are 

considered coastal waters. The BEACH Act 

specifically includes Great Lakes waters and 

marine coastal waters, including oceans and 

coastal estuaries.

The BEACH Act explicitly excludes from the 

definition of coastal recreation waters both 

inland waters and waters upstream of the mouth 

of a river or stream that has an unimpaired 

natural connection with the open sea. Figure 3-2 

illustrates this difference. The heavy lines 

indicate areas that would be considered coastal 

waters; the thin lines indicate areas that would 

not be considered coastal waters.

A state or tribe, in consultation with EPA, should 

make the classification of coastal versus 

noncoastal, taking site-specific conditions into 

consideration. 

July 31, 2014 26 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

3.2.2 Designated Uses of Water Bodies

States should consult their state WQS to determine the “designated use” for their coastal waters. 

Under CWA section 303(c)(2)(A), each WQS adopted by a state or tribe must include a 

designated use for the waters to which the standard applies, along with criteria to protect the 

use(s). 

Recreation occurs in many forms throughout the United States and frequently centers around 

water bodies and activities that take place in and on the water. Waters where people could 

engage in activities that might result in ingestion of the water or immersion are designated for 

use as primary contact recreation waters in state or tribal WQS. Such activities, for example, 

typically include swimming, water skiing, and surfing. Often a state will designate most or all of 

its surface waters for primary contact recreation. The waters adjacent to bathing beaches 

generally constitute a subset of the waters designated for primary contact recreation.

Most recreation waters are designated for year-round primary contact recreation. However, for 

some waters, a primary contact recreation use can be designated as “seasonal,” attainable only 

for several months of the year such as during warm summer months. Use designations include 

seasonal, intermittent, or other recreation uses. 

3.3 Step 2: Identify “BEACH Act” Beaches

The next step is to identify “BEACH Act” beaches as illustrated in figure 3-3. After beach 

program managers identify which coastal waters are designated as primary contact recreation, 

they should then determine which of these are considered “beaches.” The BEACH Act grant 

program is for “coastal recreation waters adjacent to beaches” or “similar points of access that 

are used by the public”—waters where swimming, bathing, and other such activities occur. In 

this document, the term beach refers to both beaches and similar points of access adjacent to 

coastal recreation waters, not physical characteristics such as substrate and the like.

Figure 3-3. Step 2: Identify beaches and similar points of access.

July 31, 2014 27 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

A beach does not have to be in the public domain to be covered by a BEACH Act grant-funded 

program. Privately owned beaches that are used by the public for swimming, bathing, and other 

water contact activities should be included in the identification, evaluation, and classification of 

beaches to meet this performance criterion.

As general guidance, beach boundaries can be defined by the following: 

• Jurisdictional boundaries or designated portions of shoreline within a jurisdictional 

boundary. 

• Natural or artificial barriers that form an up-coast or down-coast beach boundary. 

• Access factors, which include proximity to towns, roads, parking lots, visitor centers, 

shops, and other cultural landmarks. 

• Limits on services such as lifeguards and monitoring programs. 

Regardless of the factors involved, however, access and usage of the water body ultimately 

should determine whether a beach is included in a BEACH Act monitoring and notification 

program. 

3.4 Step 3: Characterize the Beach to Determine Risk and Use 

Two factors must be used in the third step (figure 3-4) to rank beaches in a BEACH Act grantfunded program: (1) factors that indicate the potential risk to human health presented by 

pathogens (section 3.4.1) and (2) use of the beach (section 3.4.2). As noted earlier, the term use

refers to the usage of a beach by the public and the term risk refers to the susceptibility of beach 

waters to contamination from fecal contamination and, therefore, the increased likelihood of 

adverse public health risks due to pathogens. 

Figure 3-4. Step 3: Characterize the beach to determine risk and use.

July 31, 2014 28 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

3.4.1 Assess Potential Sources of Contamination and Risks

The first component of step 3 involves reviewing information to help beach managers assess 

potential sources of fecal contamination and possible public health risks. The grantee may 

consider a wide range of information sources. For example, available information may reside in 

many places, including government agency files, literature and records in local libraries, beach 

management reports, community association reports, public health records, scientific papers and 

journals, and work performed by local nonprofit organizations. The information sources are 

listed in order of relative importance. 

3.4.1.1 Primary Information Sources

The most useful sources of information are sanitary surveys, reports on beach advisories and 

closings, water quality monitoring reports, water quality modeling reports, and microbial source 

tracking (MST) information.

3.4.1.1.1 Sanitary Surveys

Sanitary surveys are one of the most widely accepted tools to assess potential sources of 

pollution that might adversely affect public health. They have been employed extensively in the 

Great Lakes to evaluate sources of fecal contamination and help beach managers assess the 

magnitude of pollution. 

Beach sanitary surveys involve collecting information on factors that can affect water quality, 

such as environmental, meteorological, physical, biological, and land-based parameters. 

Examples of information collected at the beach might include the number of birds at the beach, 

slope of the beach, location and type of sewage disposal, condition of bathrooms, recent rainfall 

amounts, wind speeds and wave heights, and amount of seaweed on the beach. Information 

collected in the watershed could include land use, location of stormwater outfalls, water quality 

tributaries such as rivers and estuaries, and residential septic tank placement and function. 

Even though BEACH Act funds may not be spent for source mitigation and cleanup efforts, 

managers may use grant funds for sanitary surveys to help prioritize beaches for the List of 

Beaches. In addition, the survey results can help prioritize and allocate state or county resources 

to projects that can improve beach water quality. The survey results can also help develop 

models to predict beach water quality using readily available data (e.g., FIB levels, source flow, 

turbidity, and rainfall). 

A beach sanitary survey also provides a documented historical record of beach and watershed 

water quality. By helping beach or program managers to establish baseline conditions and 

understand water quality trends, a sanitary survey enables such managers to perform long-range 

water quality and resource planning. A sanitary survey can support enforcement actions by 

recording conditions and operations at specific points in time (e.g., sewage spills). The 

information in a survey can benefit stormwater program managers, wastewater facility managers, 

local elected officials, local planning authorities, academic researchers, and other beach and 

water quality professionals. 

July 31, 2014 29 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

For BEACH Act programs, beach managers should use surveys to help characterize health risks 

at specific beaches, prioritize beaches for monitoring and notification efforts, and focus the 

program to improve beach water quality. 

The sanitary survey consists of two types of beach sanitary surveys—the Routine On-site 

Sanitary Survey and the Annual Sanitary Survey—to assist with short- and long-term beach 

assessments, respectively. The Routine On-site Sanitary Survey is designed to be performed at 

the same time that water quality samples are collected. The Annual Sanitary Survey is more 

comprehensive and can be used to record detailed information on the beach and the surrounding 

watershed that might affect beach water quality. Both surveys include versions tailored for 

freshwater and marine beaches. For example, the freshwater survey includes information on 

septic tanks in the contributing watershed and land use information. The marine survey forms 

include detailed questions on salinity, tides, and other characteristics, which the freshwater 

surveys do not include. 

All forms are available at http://www2.epa.gov/beach-tech/beach-sanitary-surveys. 

The User Manual includes additional detailed information supporting each of these survey 

questions, including detail about human and non-human sources. Additional information about 

assessing non-human sources is also available in EPA’s RWQC technical support documents for 

QMRA.

3.4.1.1.2 Beach Notifications—Advisories and Closings

Previously issued beach notifications (i.e., advisories and closings) can provide insight into water 

quality problems. Information might include links to notifications caused by rain events, the 

frequency of notifications during the swimming season, causes of notifications (preemptive, 

outfalls, increased sampling, rain), and the number of swimming days affected by a notification. 

3.4.1.1.3 Water Quality Monitoring Reports

Reports with data on bacterial indicator densities might be helpful. State water quality 

monitoring reports often contain temperature, flow, turbidity, or other water quality data that 

might be helpful in identifying water quality patterns because many factors influence the 

temporal and spatial variability of fecal indicators in recreational waters.

A recent special issue of Water Research (Reis and Wuertz 

2013) was devoted to a large-scale, collaborative MST project 

that was coordinated by the Southern California Coastal 

Water Research Project (SCCWRP) (Boehm et al. 2013; 

Stewart et al. 2013). The project was called the Source 

Identification Pilot Project. Although the project was 

conducted only on human and animal fecal sources in 

California, it provides a state-of-the-art examination of MST 

methodological approaches and their potential application for 

source partitioning. General information on MST can be found 

at the SCCWRP website:

ftp://ftp.sccwrp.org/pub/download/DOCUMENTS/FactSheets/

SourceIDFactSheet_web.pdf. 

July 31, 2014 30 

3.4.1.1.4 Water Quality 

Modeling Reports

Predictive tools, including water 

quality models, provide useful 

information. Water quality 

reports based on modeled results 

can identify or highlight beach 

areas that might pose increased 

public health risk. Many beach 

managers have noticed a 

connection between the 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

enumeration of FIB at a beach and the amount of rain received in nearby areas (USEPA 2010). 

Models that predict bacterial contamination during rainfall events can help reduce the risk of 

swimmer exposure to contaminants between normal sampling periods. Beach managers can 

develop a series of questions or a decision tree, considering factors such as rainfall to guide 

beach notifications (USEPA 2010). Chapter 4 provides additional information on those types of 

models. 

3.4.1.1.5 Microbial Source Tracking

MST methods can help managers identify the types (e.g., human versus nonhuman) and sources 

of fecal contamination, including those from nonpoint sources. MST is based on the assumption 

that, given the appropriate method and source identifier, the source of pollution can be detected 

and quantified (USEPA 2005). Several types of analytical methods are employed for MST, and 

each has advantages, limitations, and applications. Determining which method is appropriate 

depends on the distinctive circumstances associated with the specific study area, the results of 

sanitary surveys, and budgetary and time constraints (USEPA 2005). 

For more information on MST from EPA Region 10, visit 

http://www.epa.gov/region10/pdf/tmdl/mst_for_tmdls_guide_04_22_11.pdf. Although this 

document addresses using MST in the total maximum daily load (TMDL) program, it also 

provides general background information about MST approaches. 

3.4.1.2 Other Information Sources

3.4.1.2.1 Point Source Discharge Data

Facilities authorized to discharge wastewater under the National Pollutant Discharge Elimination 

System (NPDES) program, including, but not limited to, publicly owned treatment works 

(POTWs), combined sewer systems, and concentrated animal feeding operations (CAFOs), can 

provide information on the contents, quality, history, and locations of their point source 

discharges.

3.4.1.2.1.1 Publicly Owned Treatment Works

POTWs are wastewater treatment works owned by a state or municipality (as defined by CWA 

section 502(4)) that include any devices and systems used in the storage, treatment, recycling, 

and reclamation of municipal sewage or industrial wastes of a liquid nature. The term also 

includes sewers, pipes, and other conveyances only if they convey wastewater to a POTW. 

POTWs can contribute sources of human-derived pathogens that can potentially pose a 

significant risk by adversely affecting human health. Therefore, the location, discharge loadings, 

operation, and compliance history of POTWs can be helpful to beach managers. For more 

information, visit http://cfpub.epa.gov/npdes/home.cfm?program_id=3. 

3.4.1.2.1.2 Combined Sewer Systems

Combined sewer systems are collection systems that convey domestic sewage, industrial and 

commercial wastewaters, and stormwater into a POTW for treatment. During a wet-weather 

event, a combined sewer overflow (CSO) can occur when the volume of wastewater entering a 

combined sewer system exceeds the POTW’s treatment capacity. This results in the discharge of 

July 31, 2014 31 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

excess flow directly to surface waters. CSOs contain raw sewage with high levels of floatable 

materials, pathogens, conventional and toxic pollutants, and other pollutants. Information about 

CSO events can help beach managers because such discharges can cause exceedance of WQS at 

beaches, posing risks to human health (USEPA 2001). For more information on CSOs, visit 

http://cfpub.epa.gov/npdes/faqs.cfm?program_id=5. 

3.4.1.2.1.3 Concentrated Animal Feeding Operations

CAFOs and other animal feeding operations (AFOs) can pose a number of risks to water quality 

and public health, mainly because of the amount of animal manure and wastewater they generate. 

Manure and wastewater from AFOs and CAFOs have the potential to contribute pollutants such 

as pathogens, nutrients (e.g., nitrogen and phosphorus), sediment, heavy metals, hormones, 

antibiotics, and ammonia to the environment. The NPDES permitting program defines and 

regulates CAFOs. Information about CAFOs can benefit beach managers because CAFOs might 

contribute to water quality concerns if there are discharges near beaches. For more information 

on CAFOs, visit http://cfpub.epa.gov/npdes/faqs.cfm?program_id=7. 

3.4.1.2.2 State Water Quality Assessment Integrated Reporting

A state’s integrated report is a biennial state submittal that includes the state’s findings on the 

status of all of its assessed waters (as required by CWA section 305(b)), a listing of impaired 

waters and the causes of impairment, and the status of actions being taken to restore impaired 

waters (as required by CWA section 303(d)). EPA has encouraged states to integrate water 

quality assessment information into one report. 

EPA compiles state-submitted integrated report data to develop the National Water Quality 

Inventory Report to Congress (CWA section 305(b)), determine states’ variable portion of the 

section 106 grant allocation formula, inform water quality decisions, and conduct national 

analyses with various stakeholders to help restore the nation’s waters. 

The information in a state’s CWA section 305(b) assessment typically identifies assessed water 

bodies that are in full attainment, partial attainment, or nonattainment of their designated uses. 

The 305(b) assessment is a good source of information for locating potential problem areas in 

recreational water bodies. The section 305(b) reporting information has been made available 

online through EPA’s ATTAINS database. ATTAINS includes states’ integrated water quality 

assessment reporting under both sections 305(b) and 303(d). For more information, see 

http://water.epa.gov/lawsregs/guidance/cwa/305b/index.cfm. 

A state’s CWA section 303(d) list of impaired waters includes water bodies that have been 

identified as not attaining WQS (that are considered impaired) and, therefore, require TMDLs. 

Each state must develop one or more TMDLs for all water body/pollutant combinations on the 

state’s 303(d) list. The CWA section 303(d) list might provide important water quality 

information about the potential for fecal contamination.

For more information, visit http://water.epa.gov/lawsregs/lawsguidance/cwa/tmdl/index.cfm. 

July 31, 2014 32 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

3.4.1.2.3 Nonpoint Source (CWA Section 319) Reports

Nonpoint source pollution can be caused by rainfall or snowmelt moving over and through the 

ground and carrying natural and human-made pollutants into lakes, rivers, streams, wetlands, 

estuaries, other coastal waters, and ground water. Since there are many potential nonpoint 

sources of fecal contamination, these sources can contribute to contamination at beaches. Thus, 

source identification or investigations should be factored into beach ranking decisions. Nonpoint 

source pollution also can result from resuspension of bacteria-laden beach sands and 

hydrological modification.

For more information on the CWA Section 319 Program, visit 

http://water.epa.gov/polwaste/nps/cwact.cfm. 

3.4.1.2.4 Illness Reports (Swimmer Reports or Hospital Records)

Medical records and epidemiological studies can provide information related to the historical risk 

of swimming at a beach. Swimmer illness reports or complaints to a state agency are also 

possible sources of information and can help answer the following questions: 

• Have any swimmers complained to the state agency about illnesses believed to be related 

to the water quality at the beach?

• Have any hospitals or other medical facilities documented such reports of illness? Have 

any epidemiological studies been conducted at the beach?

• Have other government agencies described health problems at the beach or adjacent 

shoreline areas?

• Approximately how many reports of illness have occurred? How many have occurred in 

the past year?

The frequency and severity of reports of swimming-associated illnesses can provide important 

insight into the risks of bathing at a beach. In many cases, however, people who contract 

illnesses as a result of bathing in contaminated water do not always associate their symptoms 

with swimming. They might associate illnesses with sources other than contaminated water. As a 

result, illness outbreaks are often inconsistently reported. States should exercise caution when 

determining the significance and validity of such data. Because interpretation of medical records 

and epidemiological information can be a complex process, professionals trained in data 

interpretation should perform this function. 

3.4.1.2.5 Environmental Group Reports

Many environmental groups conduct studies and publish reports on local beaches and 

recreational waters. The reports can help in classifying beaches because they might evaluate 

levels of pathogen indicators and identify potential sources of pollution. The reports also might 

include historical information and report how water quality conditions have changed over time. 

3.4.2 Determine Use of the Beach

The second component of characterizing a beach is determining its use. As noted at the 

beginning of this chapter, the term use refers to the usage of beach waters by the public. The 

July 31, 2014 33 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

frequency of use—and thus potential exposure to pathogens—can be measured by determining 

how many people use beach waters and when the peak periods of usage occur. The methods for 

determining beach use include counting by hand, counting from photos, counting cars in the 

parking lot, and using a laser counter at the beach entrance. Use estimates can be refined by 

considering the percentage of people visiting the beach who actually enter the water, beach use 

during holidays, the length of the swimming season, and a number of other factors. There is no 

national definition of high beach usage. The determination of beach usage and associated 

monitoring relies on a state-specific evaluation.

3.5 Step 4: Rank Beaches by Tiers 

The fourth step is to rank the beaches and assign them to tiers using the information and data 

collected in step 3 (figure 3-5).

Figure 3-5. Step 4: Rank beaches by tiers.

Once there is a clear understanding of use and potential risk from the previous step, states and 

tribes should group beaches into tiers that share a similar risk or use level or both. As noted 

earlier, risk and use must be given highest priority when ranking beaches for inclusion in the 

monitoring and notification program. However, states and tribes may consider other factors such 

as economic issues, tourism, and public opinion. 

3.5.1 Other Factors

States may evaluate other factors (e.g., importance to the local economy and community input) 

as secondary considerations in evaluating and classifying (i.e., ranking) beaches. Chambers of 

commerce and government agencies occasionally publish reports on the economic value of 

natural resources and how they contribute to the local economy. 

The state or tribe should identify these other factors and describe how they affect beach rankings. 

For example, a state or tribe might determine that it has more beaches than it can monitor with 

July 31, 2014 34 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

available resources and that beach usage presents equal risk to similar numbers of people. In this 

case, the state or tribe might review other factors to decide which beaches to include in its 

program, and which ones might either be moved to a lower tier or dropped from the program 

entirely. Beaches dropped from the program would still be “BEACH Act beaches,” but they 

would not be included in the current monitoring and notification program. 

3.5.2 Tiered Approach

EPA recommends that states and tribes consider using three tiers, and EPA’s approach (here and 

in chapters 4 and 5) is linked to such a three-tier organization. Tier 1 beaches, for example, 

would include the group of beaches a jurisdiction considers its highest priority because of high 

risk, high use, or both. Typically a higher proportion of monitoring and notification efforts would 

be devoted to this group. Tier 3 beaches would be considered significantly lower on the risk/use 

scale. Risk might be judged lower, for example, because of consistently good water quality as 

evidenced by monitoring results. Tier 2 beaches fall somewhere in between. 

3.6 Step 5: List of Beaches—Classify Beaches into “Program” Versus 

“Non-program” Beaches and Incorporate Them into a Final State 

List of Beaches

The fifth and final step (figure 3-6) is to use the ranked beaches from Step 4 to complete the state’s or 

tribe’s List of Beaches. In this document, EPA refers to the resulting list of BEACH Act beaches and 

their adjacent waters—showing those which are included in the monitoring and notification program 

and those which are not—as the List of Beaches. States and tribes need to identify their lists and 

submit them to EPA consistent with CWA sections 406(b)(2)(A)(iv)6 and 406(c)(1). EPA will rely 

on this information to help fulfill its obligations under CWA section 406(g).

Figure 3-6. Step 5: Complete the List of Beaches.

6 CWA section 406(b)(2)(A)(iv) directs states to provide a “list of discrete areas of coastal recreation waters that are 

subject to the program for monitoring and notification for which the grant is provided that specifies any coastal 

recreation waters for which fiscal constraints will prevent consistency with the performance criteria . . . .”

July 31, 2014 35 

 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

Program and non-program beaches are defined as follows:

• Program beaches are beaches and their adjacent waters subject to a state’s or tribe’s

BEACH Act monitoring and notification program, consistent with the performance

criteria.

• Non-program beaches are BEACH Act beach waters that are not subject to a state’s or

tribe’s program, including those beach waters for which fiscal constraints prevent

consistency with the performance criteria. Non-BEACH Act beaches would not be

included in the List of Beaches regardless of their monitoring status because they would

be eliminated during steps 1 and 2, as discussed earlier in this chapter.

Table 3-2 shows how a state or tribe might organize its List of Beaches. 

Table 3-2. Example of a List of Beaches

Beach Rank #

Beaches ranked individually 

by risk, use, or both)

Tier

Beaches grouped by tiers, 

based on risk, use, or both)

Monitoring and Considerations

(Add detail according to 

determinations in chapters 4 and 5*)

Program beaches

Beaches subject to the state’s or tribe’s BEACH Act monitoring and notification program

Tier 1

1

2

3

Tier 2

4

5

Tier 3

6

7

8

Non-program beaches

Beaches not subject to the state’s or tribe’s BEACH Act monitoring and notification program

9

10

*Chapter 4 provides in-depth information on the requirements and recommendations for developing a detailed monitoring plan. It

addresses such topics as sources of variability, sampling depth, locations, resampling, analytical methods (e.g., culture versus 

qPCR), modeling, analytical approaches, and quality assurance and control. Chapter 5 provides in-depth information on how to 

develop a detailed risk communication and notification plan. It addresses such topics as types of notifications, signs, locations, 

frequency, risk communication, and other considerations.

EPA recommends that each beach on the list include relevant information such as beach name, 

beach ID number, location, rank, and monitoring frequency. 

July 31, 2014 36 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

3.6.1 Initial Submission to EPA

The state’s or tribe’s List of Beaches must be submitted to EPA after the state or tribe has given 

the public an opportunity to review it. 

The BEACH Act authorizes EPA to award implementation grants only if the public is provided 

an opportunity to review the grant-funded monitoring and notification program through a process 

that provides for public notice and the opportunity to comment on the program, which would 

include ranking of beaches. (See performance criterion 10, section 2.2.10.) A state or tribe 

should review and address any public comments before submitting its List of Beaches to EPA.

3.6.2 Revising and Updating the List of Beaches

EPA expects that a state’s or tribe’s beach program will evolve over time and that its List of 

Beaches will be a living document that is updated to reflect changing circumstances, such as 

funding levels and evolving priorities. One specific requirement for performance criterion 1 (see 

table 3-1) is that a state or tribe must notify EPA at least annually if the List of Beaches changes 

significantly. These changes could include revised beach rankings, changes to monitoring and 

notification requirements, or other important considerations. Therefore, a state or tribe must 

review its program and associated List of Beaches annually to determine whether there are 

significant changes and, if so, must provide the public with an opportunity to review these 

significant program changes and discuss them with its EPA regional beach coordinators. States 

and tribes must submit the information to EPA in the form of a revised state List of Beaches.

3.7 Federal Beaches

The federal government is responsible for BEACH Act beaches on federal property, consistent 

with CWA section 406(d). BEACH Act grant funds may not be spent for monitoring or 

notification at federal beaches. Moreover, states do not need to report information on those 

beaches to EPA or include them in their List of Beaches.

3.8 Chapter 3 References

Boehm, A.B, L.C. Van De Werfhorst, J.F. Griffith, P.A. Holden, J.A. Jay, O.C. Shanks, D. 

Wanga, and S.B. Weisberg. 2013. Performance of forty-one microbial source tracking 

methods: A twenty-seven lab evaluation study. Water Research 47: 6812–6828. 

Reis, M., and S. Wuertz, ed. 2013. Microbial Source Tracking [issue title]. Water Research

(47)18: 6811–6956. 

Stewart, J.R., A.B. Boehm, E.A. Dubinsky, T. Fong, K.D. Goodwin, J.F. Griffith, R.T. Noble, 

O.C. Shanks, K. Vijayavel, and S.B. Weisberg. 2013. Recommendations following a 

multi-laboratory comparison of microbial source tracking methods. Water Research

47(18): 6829–6838. 

USEPA (U.S. Environmental Protection Agency). 2001. Guidance: Coordinating CSO LongTerm Planning with Water Quality Standards Reviews. EPA-833-R-01-002. U.S. 

Environmental Protection Agency, Office of Water, Washington, DC. 

July 31, 2014 37 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 3 

———. 2005. Microbial Source Tracking Guide. EPA-600/R-05/064. U.S. Environmental 

Protection Agency, Office of Research and Development, Washington, DC. 

———. 2010. Predictive Tools for Beach Notification. Vol. 1, Review and Technical Protocol. 

EPA-823-R-10-003. U.S. Environmental Protection Agency, Office of Science and 

Technology, Washington, DC. 

July 31, 2014 38 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

Chapter 4: Beach Monitoring

Chapter 3 laid out a step-by-step process by which a state or tribe can conduct an evaluation and 

classification of its beaches, resulting in a List of Beaches that is ranked in tiers determined on 

the basis of potential risks to public health, beach usage, and other key factors (section 3.6). 

Key changes to chapter 4 from the 2002 guidance document

• Strengthens the link between prioritizing beaches and developing a tiered monitoring 

plan (sections 3.5, 3.6, and 4.2).

• Adds three specific requirements to performance criterion 2 (section 4.1).

• Updates the science on beach water quality monitoring (section 4.3).

• Updates monitoring procedures to include qPCR (section 4.4.2).

• Adds a specific requirement to report monitoring data to the public on a website

(section 4.5).

• Expands the discussion on integrating predictive models into a monitoring plan (section

4.6).

• Adds discussion of the beach monitoring program within the context of the 2012 RWQC,

including adoption of new or revised WQS pursuant to CWA section 303(i)(1)(B) and

identification and use of a beach notification threshold (section 4.7).

Monitoring has evolved to include a number of support tools, including sampling, sanitary 

surveys, and predictive tools. Chapter 4 describes the performance criteria and technical 

guidance related to beach monitoring and assessment procedures for identifying short-term 

increases in FIB. It also provides information on how to develop a tiered monitoring plan based 

on local circumstances using the risk-based classification of beaches discussed in chapter 3. The 

contents of the sections of this chapter are as follows:

• Section 4.1: A description of the performance criteria that relate to monitoring and

assessment.

• Section 4.2: The concept of a tiered monitoring plan, including goals, considerations, and

an example plan, along with requirements and recommendations for quality assurance

(QA).

• Section 4.3: Detailed information on how to structure a monitoring program to assess

beach water quality, including recommended monitoring and analytical procedures.

• Section 4.4: A discussion of methods and procedures, including consideration of rapid

methods.

• Section 4.5: A discussion about monitoring report submission.

• Section 4.6: Ways to incorporate predictive tools into a beach monitoring and notification

program.

• Section 4.7: A discussion about the 2012 RWQC and beach monitoring programs.

• Section 4.8: A discussion of delegation of monitoring responsibilities.

July 31, 2014 39 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

The chapter includes monitoring approaches appropriate for both culture and qPCR methods for 

determining FIB densities. Where approaches differ, the specific differences are clearly noted. 

Many monitoring procedures are common to both methods of water quality analysis. 

Integrating sanitary surveys into beach monitoring planning, using predictive tools in beach 

management, and potentially using qPCR methods are valuable approaches that can be used for 

beach monitoring, and they are emphasized in this document. EPA encourages beach or program 

managers to be flexible when tailoring monitoring plans to their beach settings to optimize public 

health protection by using a range of these available tools.

4.1 Performance Criteria

Additions to the monitoring and assessment performance criteria pave the way for states and 

tribes receiving beach grants to implement significant improvements to public health protection 

by widespread use of sanitary surveys to identify sources of fecal pollution; the use of qPCR 

analysis and predictive modeling, which facilitate same-day notification of water quality 

exceedances; timely reporting of water quality results; and tailored WQS for site-specific public 

health protection. 

Table 4-1 summarizes the general and specific requirements of the five performance criteria 

related to monitoring and to the beach assessment activities that go into forming a monitoring 

plan (criteria 2 through 5 and 10) and cross-references them to the sections in this chapter that 

discuss them. The term assessment, used in this context, means gathering information to serve as 

a basis for a monitoring plan, as distinct from the assessment activities associated with routine 

monitoring of ambient waters under CWA section 305(b). 

Table 4-1. Summary of monitoring performance criteria

Performance criteria Chapter 

General requirement Specific requirements section

Tiered Monitoring Plan 

(Performance Criterion 2).

Performance criterion 2 

requires development of a 

tiered monitoring plan that 

can adapt to changing 

conditions and adequately 

protect public health.

• Adequately prioritize, in the tiered monitoring plan, the frequency,

locations, and methods of monitoring and assessment of coastal

waters based on:

o A review of existing monitoring data.

o Periods of recreational use of the waters.

o The nature and extent of use of the waters.

o The proximity to known point and nonpoint sources of pollution.

o The effect of stormwater runoff on the waters.

o The appropriateness of qPCR methods.

o The potential use of predictive tools.

• Provide for public review of the tiered monitoring plan.

• Develop appropriate quality control (QC) policies and procedures and

submit adequate quality management plans (QMPs) and quality

assurance project plans (QAPPs) to EPA for approval.

4.2 and 

4.3

2.2.11

4.2.3

July 31, 2014 40 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

Performance criteria Chapter 

General requirement Specific requirements section

Methods and Assessment 

Procedures (Performance 

Criterion 3). Performance 

criterion 3 requires the 

development of detailed 

methods and assessment 

procedures. 

• Submit to EPA methods for characterizing water quality relative to

human health in coastal recreation areas.

• Provide documentation of the performance of methods other than

those that EPA recommended or approved or validated.

• Identify and submit to EPA procedures for assessing short-term

increases in FIB densities that indicate risk to human health in coastal

recreation waters.

4.4

Monitoring Report 

Submission (Performance 

Criterion 4). Performance 

criterion 4 requires 

development of a 

mechanism to collect and 

report monitoring data in 

timely reports.

• Make monitoring data available to the public, including posting on a

website.

• Report monitoring data to EPA at least annually or at a frequency that

the EPA Administrator determines. Reported data must be consistent

with the reporting requirements specified at

http://water.epa.gov/grants_funding/beachgrants/datausers_index.cfm.

4.5

Delegation of Monitoring 

Responsibilities 

(Performance Criterion 5)

States must describe any 

delegation that they have 

made, or intend to make, to 

local governments.

• If a state delegates monitoring responsibilities to local governments,

the state grant recipient must describe the process that the state

follows.

4.8

Adoption of New or 

Revised WQS and 

Identification and Use of a 

Beach Notification 

Threshold (Performance 

Criterion 10) Performance 

criterion 10 requires states 

and tribes to develop and 

implement schedules 

leading to adoption of new 

or revised WQS and for the 

identification and use of an 

appropriate beach 

notification threshold.

• Develop and implement two separate schedules:

o To adopt new or revised WQS by FY 2016.

o To identify and use a beach notification threshold by FY 2016.

• Before identification and use of a new beach notification threshold,

continue to make beach notification decisions using the existing

threshold based on the currently applicable WQS, e.g., SSM.

4.7.3

Performance criterion 2 now requires states and tribes receiving beach grants to consider the 

following elements when developing a tiered monitoring plan: 

• A review of existing monitoring data. The BEACH Act states have been implementing

beach monitoring programs since at least 2000, and since that time they have amassed

large amounts of recreational water quality data. These data provide a substantial

characterization of water quality at monitored beaches and are likely to prove useful in

formulating monitoring plans as well as in supporting model development. States and

tribes must now consider these historical data when developing a tiered monitoring plan.

• The appropriateness of qPCR. The 2012 RWQC make available a number of tools to

assist beach managers in implementing monitoring and notification programs. qPCR is a

rapid molecular method that facilitates same-day notifications when beach water quality

presents a risk to public health. It also presents challenges, including method

July 31, 2014 41 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

performance. However, given the potential for same-day notifications and the public 

health protection that qPCR could provide, states and tribes must now consider when 

developing tiered monitoring plans whether qPCR might be appropriate at specific sites.

For states and tribes that know they do not have the resources or expertise to implement 

qPCR, or that practical factors such as proximity to laboratory facilities would preclude 

its use, “consideration” of qPCR could take the form of a brief acknowledgment in the 

grant workplan that, at the present time, the state or tribe has determined that qPCR 

cannot be implemented. For states and tribes that believe there might be beaches where 

qPCR could be implemented, “consideration” could involve developing a plan to perform 

a site-specific analysis.

• The potential use of predictive tools. Another tool discussed in the 2012 RWQC is 

predictive modeling. Like qPCR, modeling offers the potential for same-day notification, 

but for a considerably smaller resource outlay than qPCR. The 2012 RWQC encourages 

states and tribes to use site-specific models as part of a tiered monitoring plan. Given the 

potential for same-day notifications and the public health protection that modeling could 

provide, states and tribes must now consider when developing tiered monitoring plans 

whether predictive models might be appropriate at specific sites.

State level of effort in considering the use of predictive models will also be on a 

continuum, based on a state’s or tribe’s knowledge of their applicability (e.g., states with 

beaches with very good water quality might already know that models do not work well 

in those environments), local circumstances, and available resources. 

The level of effort a state or tribe puts into considering the use of qPCR or predictive models 

may vary depending on the suitability of these tools and the state’s or tribe’s ability to implement 

them, including whether the state or tribe has sufficient resources.

Performance criterion 4 adds a requirement to post monitoring data on a website, to ensure its 

wide public availability.

A new performance criterion 10 requires states and tribes to develop and implement schedules to 

adopt new or revised WQS pursuant to CWA section 303(i)(1)(B) and to identify and use an 

appropriate beach notification threshold. 

4.2 Developing a Tiered Monitoring Plan (Performance Criterion 2)

This section describes the required elements of a tiered monitoring plan and discusses QA 

requirements and recommendations. Developing the tiered monitoring plan starts with the ranked 

List of Beaches described in chapter 3. 

4.2.1 Goal and Key Considerations

The goal of a tiered monitoring plan is to define combinations of monitoring activities that align 

with identified priorities (i.e., tiers), are appropriate for the level of risk and use of a given beach, 

effectively allocate available monitoring resources, and address site-specific circumstances. A 

BEACH Act grant-funded program must prioritize the use of grant funds for monitoring on the 

July 31, 2014 42 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

basis of the use of the waters and the risk to human health. A beach or program manager should 

consider the following factors when developing a detailed tiered monitoring plan: 

• EPA requirements and policy recommendations for BEACH Act grants. 

• Existing and historical beach water quality.

• Sampling considerations. 

• Analytical methods.

• Available funding and staffing. 

• Logistical considerations.

• Potential use of predictive tools.

The specific elements of monitoring plans will vary according to these factors, local practices 

and policies, and the extent and nature of available resources. Regardless of the approach taken, 

states and tribes must demonstrate how the plan meets the performance criterion for an adequate 

tiered monitoring plan. 

The number of tools available to states and tribes has increased in recent years. In 2002, when 

the first beach guidance was issued, the primary decisions involved in the development of a 

tiered monitoring plan included choosing which beaches to monitor and how often to monitor 

them. The number of potential considerations has increased. Now states and tribes should factor 

in information related to the following additional questions: 

1. What does the history of water quality monitoring at this beach reveal about how often it 

requires monitoring?

2. How can sanitary survey findings be used to tailor monitoring approaches? 

3. What is the most appropriate method of measuring water quality at this beach—culture or 

qPCR methods—relative to sources of contamination, the number and type of people 

visiting the beach (e.g., many families with small children), and available resources?

4. If it appears that a beach is a good candidate for qPCR, do practical factors such as 

proximity to laboratory facilities allow timely notification?

5. Is this beach a good candidate for a predictive model or other predictive tool in terms of 

observed effects from sources under varying conditions? 

6. Are staff members with experience in model development available? 

7. How can the use of available resources be otherwise optimized to best protect public 

health?

July 31, 2014 43 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

4.2.2 Tiered Monitoring Plan

Table 4-2 presents an example of how the various tools available to a beach or program manager 

might be incorporated into a tiered monitoring plan to maximize public health protection at a 

range of beach settings with varying risk and use characteristics. As chapter 3 described, in 

EPA’s recommended tiering system, each tier shares a common level of risk (based on sources 

and variable water quality) and degree of use by the public. In the example in table 4-2: 

• Tier 1 = high risk and high beach usage.

• Tier 2 = high or moderate use and moderate or low risk.

• Tier 3 = low use and low or very low risk.

The tools include: 

• Sanitary surveys.

• Methods and indicators.

• Monitoring frequencies.

• Predictive models or other predictive tools.

Table 4-2. Example of a tiered monitoring plan

Rank #

(risk/

use) Tier

Examples of application of tiered monitoring to a range of beach settings

Analytical 

method

Monitoring 

frequency Model Contributing factors Additional information

Program (P) beaches

1 P-1 qPCR 5–7 

days/week

No Nearby lab with qPCR 

capability; high use; high 

risk

High-use urban beach

2 P-1 qPCR 3 days/week Yes Nearby lab with qPCR 

capability; high use; high 

risk; modeling experience

Use of model as a 

means of reducing 

analytical cost through 

targeted monitoring 

3 P-1 Culture 3 days/week Yes Lab with culture capability 

only; high use; high risk; 

modeling experience

Timely water quality 

estimates daily from a 

model

4 P-2 Culture Weekly Yes High use; moderate risk Model reduces 

analytical cost

5 P-2 Culture Weekly Rainfall 

advisory

Moderate use; moderate 

risk

Rainfall advisory 

supported 

6 P-2 Culture Every 2 

weeks

No High-moderate use; low 

risk

Rare exceedances

7 P-3 Culture None or 

infrequent

Rainfall 

advisory

Low use; low risk Rare exceedances or no 

history of exceedances

Non-program (NP) beaches

8 NP None None Rainfall 

advisory

Low use; very low risk Remote location

9 NP None None Low use; very low risk Remote location;

sporadic use

10 NP None None Low use; very low risk Resource limitation

July 31, 2014 44 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

Results from sanitary surveys can help a manager classify beaches into tiers and select the most 

appropriate tools for the monitoring program. Not every jurisdiction will use every tool in its 

monitoring program. The right mix of tools for beach monitoring programs depends on the 

setting, the resources available, the capabilities and approaches taken by the local jurisdiction in 

meeting the public health protection function, and the tiered List of Beaches.

As mentioned in section 4.2.1, the local beach manager’s selection of tools will likely depend in 

part on the capabilities and practices specific to the jurisdiction. Resource availability or public 

interest might influence a local beach manager to choose to develop local modeling capability as 

a means of stretching resources or to adopt qPCR analysis in response to local demand or the 

new availability of qPCR at a local public health laboratory. Section 4.4.2 includes other factors 

related to the selection of test methods for the applicable WQS (i.e., culture methods versus 

qPCR).

States and tribes must determine which beaches to monitor and which beaches not to monitor 

using an analysis of their recreational waters based on the degree of recreational use of the 

adjacent water body and risk to human health posed by known or unknown sources and historical 

variable water quality. According to historical data that the states and tribes submitted to EPA, 

some open-ocean marine beaches have never had a WQS exceedance. If the same beach has high 

rates of beach usage, and is an important beach to a locale or municipality, then that beach would 

still be considered important for continued monitoring. A beach with no exceedances and low 

use could be considered for reclassification as a non-program beach (i.e., a beach not subject to 

the monitoring and notification program). Such waters could be included in the state’s or tribe’s 

routine water quality monitoring program for CWA sections 305(b) and 303(d) (attainment and 

listing) purposes to confirm continued good water quality in settings where there is no history of 

WQS exceedances.

EPA recommends a tiered monitoring approach that prioritizes the use of funds based on beach 

usage and human health risk while taking into account additional relevant factors. Such a policy 

allows flexibility to states and tribes, recognizing that there might not be uniform monitoring 

requirements for all beaches. To best protect public health, the states and tribes must evaluate the 

trade-offs of monitoring more beaches less frequently or fewer beaches more frequently based on 

degree of use of the beach, risk to human health, and other considerations. For example, qPCR 

sampling could be used on days when a model predicted an exceedance of a WQS, and a 

prediction of good water quality could be confirmed after the fact with the results from a less 

expensive culture sample. Conversely, a model could replace sampling on some high-use days to 

provide timely notification. In addition, beach managers should consider all available 

information to reconcile or evaluate conflicting or anomalous analytical results, or results that 

seem inconsistent with environmental conditions. Comparing the outputs of multiple tools (e.g., 

monitoring results, model outputs, daily sanitary survey information), to the extent they are 

available, can help managers make informed assessments concerning their beaches’ water 

quality. 

4.2.3 Quality Management System Requirements for Performance Criterion 2

To meet the quality management portion of performance criterion 2 (development of an adequate 

tiered management plan), states and tribes must develop an appropriate QC system that includes 

July 31, 2014 45 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

adequate policies and procedures and submit them to EPA for approval. States and tribes must 

submit documentation of the quality system for review and approval by the EPA Grants Officer 

and the EPA QA officer, or an approved designee, before environmental measurements (primary 

or secondary) are taken. States and tribes should contact the EPA regional QA officer for more 

detailed guidance tailored to their grants. 

EPA is committed to ensuring the quality of environmental data used in its decision-making 

process and in activities supported by the Agency. As a result, EPA has developed an Agencywide quality system to ensure that environmental data are of sufficient quantity and quality to 

support the data’s intended use. EPA OW has, in turn, developed a QMP for its activities (the 

OW QMP; USEPA 2009c) that is consistent with the Agency-wide quality system. Furthermore, 

the tasks performed under BEACH Act grants involve environmentally related measurements 

and data generation, and thus they are covered by 40 CFR part 31 for grants and cooperative 

agreements to states, tribes, and local governments. To comply with 40 CFR 31.45, grant 

recipients must develop and implement QA practices consisting of policies, procedures, 

specifications, standards, and documentation necessary to produce data of sufficient quality to 

meet project objectives and to minimize loss of data due to out-of-control conditions or 

malfunctions. 

The grant recipients’ consultation with EPA regional officials should determine what 

documentation is sufficient to describe the quality system used for their beach monitoring and 

notification programs and should consider a variety of quality management topics, including but 

not limited to the following:

• Ensuring that QA procedures are consistent with EPA’s Policy Directive Number FEM2012-02, Policy to Assure the Competency of Organizations Generating Environmental 

Measurement Data under Agency-Funded Assistance Agreements. A copy of the policy 

is available online at http://www.epa.gov/fem/pdfs/competency-policy-aaia-new.pdf. 

• Developing a QAPP or equivalent documentation for their beach monitoring and 

notification programs. A QAPP is a commonly used form of documentation for primary 

data collection. It is a technical planning document that defines the objectives of a project 

or continuing operation and the methods, organization, and quality management activities 

necessary to meet the project or operation goals. It serves as the blueprint for 

implementing the data collection activity to ensure that the program’s technical and 

quality goals are met. It also provides the necessary link between the required data 

quality constraints and the sampling and analysis activities to be conducted. A QAPP 

typically details the technical activities and QA and QC procedures that should be 

implemented to ensure that the data meet the specified standards. The QAPP should be 

implemented to ensure that data collected and analytical data generated are complete, 

accurate, and suitable for the intended purpose. 

• Considering standard operating procedures (SOPs), which can be included as attachments 

to the tiered monitoring plan or QAPP and can be used to present in detail the method for 

a given technical operation, analysis, or action in sequential steps. An SOP includes 

specific sites, sampling locations, equipment, materials, and methods; QA and QC 

procedures; and other factors necessary to perform sampling, analysis, and notification. 

• Addressing other tasks identified by EPA regional officials.

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4.3 Factors to Consider When Developing a Monitoring Plan

One of the major issues a beach or program manager must confront is the significant variability 

inherent in beach water quality. This section provides information on how beach water quality 

can affect the design of a monitoring program, recommended monitoring procedures, logistical 

considerations for conducting a monitoring program, and recommendations for securing 

laboratory services and choosing appropriate analytical methods. EPA published a thorough 

review of scientific studies related to beach monitoring entitled Sampling and Consideration of 

Variability (Temporal and Spatial) for Monitoring of Recreational Waters (USEPA 2010c). This 

section summarizes the major findings. For more information see 

http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P12-

MonRept-final_508.pdf. 

4.3.1 Variability of Beach Water Quality

4.3.1.1 Temporal Variations in Sources of Fecal Indicators and Pathogens

FIB densities in water samples are highly variable across time (temporal variability) and location 

(spatial variability) at a beach. Temporal variability in FIB density—at time scales ranging from 

minutes to months—has been observed in time series analyses of FIB density (Taggart et al. 

1992). Variations with time scales on the order of minutes are important because such 

considerations influence the number of samples needed to accurately characterize microbial 

water quality and the confidence with which to ascribe the results of sampling events. Variations 

with time scales on the order of tens of minutes are important because they have the same time 

scale as that of typical recreational use 

episodes. Variations with time scales 

on the order of a day are important 

because knowledge of them allows 

comparison between samples taken at 

different times of the day or between 

samples taken on successive days. 

Temporal variability can also be 

caused by both environmental and 

meteorological parameters such as 

sunlight intensity and temperature 

(USEPA 2010c). 

Although there can be site-specific 

differences, many factors contribute to 

temporal variations in FIB density for 

both coastal and inland sites. 

Figure 4-1 depicts the relative level of 

effects on FIB densities.

Figure 4-1. Relative contributions to temporal variations 

in FIB density. (Line length indicates duration of 

influence.)

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

4.3.1.1.1 Event-Scale Variability

Event variability refers to the change in FIB density associated with rain events. Event-scale 

variabilities constitute the category of greatest variability (including both temporal and spatial 

variabilities) in FIB density for both coastal and inland waters. Rainfall events account for a 

large portion of the total FIB loading into receiving water systems. In addition, among the 

documented temporal variations, event-scale variability is, by far, the greatest for both inland and 

coastal waters. FIB density can increase by several orders of magnitude during a single rainfall 

event. FIB loading varies significantly during rain events and is related to rainfall intensity and 

duration, total rainfall amount, and antecedent rainfall patterns. Because event variability is so 

great, beach or program managers might use alternatives to FIB densities for assessing water 

quality during and after rainfall or storm events. For example, the correlation between historical 

rainfall and FIB data might allow the estimation of the total rainfall amount over a 24-hour 

period above which beaches are likely to exceed existing WQS. 

For inland sites and coastal sites affected by hydrologic features such as streams and drainage 

outfalls, FIB densities sometimes correlate poorly with rainfall amounts and stream gauges 

because of the dependence of FIB response on factors such as antecedent rainfall and the input of 

FIB from sources such as CSO discharges. In general, indicator density peaks during the rising 

limb of the storm hydrograph when loading to the stream is high and streams are turbulent, 

promoting re-suspension of sediment-associated indicators. The lag period between the 

beginning of rainfall events and sharp rises in indicator density varies among sites, with small, 

flashy streams exhibiting shorter lag periods and coastal sites exhibiting longer lag periods. 

Generally, indicator densities decline faster than the hydrograph because of depletion of 

indicators from land surfaces and other reservoirs as they are washed out. The time it takes for 

the indicator density in a stream or lake to recede to pre-storm levels is highly variable among 

drainages and even for a given drainage. Similar trends have been observed for coastal sites. 

Indicator densities rise quickly during storms because of loading from stormwater runoff, 

nearshore sands, and increased wave action and mobilization of indicators from sediments. 

Presumably, dilution would cause event-scale variability to be less at coastal sites than in 

streams, though poor mixing in the vicinity of stream mouths and stormwater outfalls appears to 

contribute to extreme event-driven changes in indicators. 

4.3.1.1.2 Diurnal (Daily) Variability

A limitation of culture methods for the analysis of beach water samples for FIB is that the results 

are available a minimum of a day later. By the time the results are received, the water quality at 

the location sampled is likely to have changed. Leecaster and Weisberg (2001) analyzed a large 

set of total coliform and fecal coliform data from samples collected at Southern California 

beaches in an attempt to associate sample collection frequency with misidentifying exceedances 

of FIB WQS in coastal waters. The lag time between sampling and analysis completion was not 

considered. Table 4-3 presents the number of missed exceedances for four sampling frequencies. 

One explanation for the poor performance of the schemes considered is the frequency of 

exceedances of single-day duration. Approximately 70 percent of exceedances lasted for only a 

day. The exceedances were characterized by water quality only slightly exceeding standards. 

Given the variabilities and uncertainties associated with sample collection and analysis, there is a 

high probability for misclassification of water quality for samples with FIB densities near or 

within the confidence interval of the existing standard. 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

Table 4-3. Percent of exceedances missed for different sampling frequencies

Sampling frequency % missed exceedances

5 days per week (weekdays only) 20%

3 times per week 45%

Once per week 75%

Once per month 95%

Source: Adapted from Leecaster and Weisberg (2001).

4.3.1.1.3 Tidal Variability

Low tides are associated in most cases with higher FIB densities at coastal sites. This association 

is typically a result of increased freshwater input to estuarine and coastal locations during low 

tide, given the direction of water flow. In a minority of circumstances, such as when rising tides 

cause connections with contaminated surface waters during a hurricane or tropical storm, 

hydrological connection of sewage and stormwater conveyance systems can occur. In general, 

tidal variability is minor compared with diurnal and rainfall variability.

Approaches for accounting for tidal variation of FIB density in developing sampling schemes 

include sampling without regard to tidal cycles and sampling at low tide or the portion of the 

tidal cycle during which FIB density is highest (all other factors being equal). 

4.3.1.1.4 Monthly and Seasonal Variability

Most U.S. inland streams experience higher FIB densities during the spring and summer than 

during the winter. That phenomenon arises from generally lower precipitation and runoff during 

summer months combined with greater loading from sources such as wildlife and domestic 

animals (particularly those with seasonal access to streams) and bacteria growing in nearshore 

soils or sediments. In tropical locales such as Hawaii, Puerto Rico, and south Florida, differences 

in seasonal precipitation patterns and other climatic factors can give rise to peak indicator density 

in other seasons. For sites where recreational use spans only the summer months, variation in 

indicator density with season does not influence the design of monitoring programs. Similarly, 

seasonal and monthly variability of fecal indicators at coastal sites is difficult to assess and tends 

to be linked to the wide range of climates existing along the U.S. shoreline and its indirect 

consequences on indicator density (e.g., loading patterns that vary with season). At both inland 

and coastal settings, seasonal and monthly variability of fecal indicator organisms is of lesser 

significance than event-scale variability.

4.3.1.1.5 Short-Time Variability

Short-time variability describes rapid changes in FIB density occurring even when sample 

collection is conducted at intervals as short as 1 to 10 minutes. Variations in the density of the 

Enterococcus spp. greater than the WQS can occur between adjacent samples taken at those time 

scales (Boehm 2007), and certainly variations can occur more quickly than the results of 

previous sampling can be obtained using culture methods. 

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4.3.1.2 Relative Magnitude of Spatial Variation

Spatial variability relates to the alignment of 

sources at a beach, advection, and the distribution 

of mixing on the beach (USEPA 2010c). Although 

site variations can alter the relative dependence of 

indicator density on sample location, the expected 

general dependence of indicator density variability 

with location for coastal sites is shown in 

figure 4-2. Studies have shown that for coastal 

sites, there is a general trend toward decreasing 

indicator density with water column depth (USEPA 

2010c). 

For inland water sites, the expected variation is 

slightly different from that for coastal sites, as 

shown in figure 4-3. For inland lakes, however, 

there is a general trend toward higher FIB density at the bottom of the water column (USEPA 

2010c). 

Features that promote or inhibit mixing and point sources of fecal indicator organisms play a 

significant role in the distribution of indicators. These features, which can be identified during a 

sanitary survey, include: 

Figure 4-2. Relative contributions to spatial 

variation at coastal beaches.

Figure 4-3. Relative contributions to spatial 

variation at inland beaches.

• Jetties, dams, or other features that 

influence mixing at a site or reduce the 

natural flow of water and therefore can 

retain contamination at a beach.

• Point sources, particularly stormwater or 

wastewater treatment discharges, in the 

vicinity of the beach. 

• Other diffuse sources of contamination 

such as small ponds and areas where wild 

birds and animals congregate, dog parks, 

and livestock and agriculture operations 

near beaches.

4.3.2 Recommended Monitoring

Monitoring programs range from simple to complex, depending on the setting. The range in 

beach settings is vast—from pristine settings to heavily used urban beaches. For every beach, 

there is an appropriate monitoring plan that addresses the risk and use characteristics chapter 3 

described. 

The following sections provide recommendations for basic sampling frequency and monitoring 

procedures a state should consider in developing its monitoring plan. Not all settings will call for 

using the range of options listed in table 4-2. This section includes an example of a basic threetiered plan, which is one recommended approach. In addition, careful observation by beach or 

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program managers of circumstances under which poor water quality occurs through the use of a 

daily sanitary survey or other process could provide the basis for focused sampling or preemptive 

advisories. 

4.3.2.1 Sampling Considerations

EPA recognizes that variation in indicator bacteria densities is one of the main technical 

challenges that beach or program managers face when designing effective monitoring programs 

and interpreting sampling results. FIB densities at different sites can substantially vary (spatially 

and temporally). Accordingly, managers should tailor monitoring plans to individual 

circumstances. The tiered monitoring plan should address specific monitoring procedures, 

including sampling time, location, and depth. Each of these is described in more detail below. 

4.3.2.1.1 Sampling Frequency

EPA recommends that samples be taken one or more times per week during the swimming 

season at Tier 1 beaches and once per week at Tier 2 beaches, starting a month before the 

swimming season. Sample as close as possible to the peak swimming period of the week (usually 

the weekend), while still allowing time for retesting and notification on subsequent days. 

Sampling frequencies should be consistent with the circumstances at a beach. For example, many 

agencies sample Tier 1 beaches more frequently to minimize the uncertainty in their sampling. 

Conversely, less frequent sampling might be appropriate for Tier 2 or greater beaches, depending 

on distance to suspected pollution sources, beach use, historical water quality data, and other risk 

factors.

For Tier 3 beaches, EPA recommends a minimum sampling frequency consistent with other 

ambient water quality sampling programs. However, these beaches should be reviewed 

periodically to determine whether they should be reclassified as Tier 1 or Tier 2 or non-program 

beaches. Such an assessment should include a review of beach use, an updated sanitary survey, 

and a review of the water quality history and resulting advisories. 

When sampling for qPCR analysis, if possible, sample on every day of significant swimming 

activity for same-day notification. If this is not possible, sample on the peak swimming days for 

same-day as well as subsequent-day notification and retesting. Rapid methods can also influence 

the selection of sampling frequencies. Rapid methods might promote the public expectation of 

daily monitoring at heavily used beaches where same-day notification of exceedances has been 

provided on some days. 

4.3.2.1.2 Sampling Frequency and Predictive Models

A predictive model can be used to complement analytical test methods for the applicable WQS

(e.g., culture or qPCR methods), reducing the frequency of sampling, depending on the 

circumstances and setting of a beach. Data from culture samples can be used as a basis for 

models that provide timely results in a cost-effective manner. In addition, historical data are now 

available for most monitored beaches. 

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The time period covered by the data used to build robust models can vary in length, depending 

on the beach setting. According to varying trend analyses conducted by the U.S. Geological 

Survey (USGS), the suggested minimum data collection period is roughly two years (Gonzalez et 

al. 2012), whereas some EPA modeling trials obtained favorable results from data collected over 

45 days (Frick et al. 2008). In addition, using a model should not completely replace monitoring 

(USEPA 2010c). If the locally selected threshold for predictive errors is maintained at a lower 

monitoring frequency (e.g., twice per week to once per week) after building a model on the basis 

of twice per week, the model can save scarce monitoring resources for use at another location 

where a model might not be appropriate. 

4.3.2.1.3 Timing of Sample Collection

Collecting samples early in the morning for culture analysis appears to offer the best balance 

between practicality and generation of data that protect human health (USEPA 2010b). If culture 

methods are used for enumerating FIB, morning samples could generate results that would allow 

posting of health advisories the next morning. 

For culture methods, FIB densities tend to be lower in the afternoon, probably because of the 

effects of sunlight. Diurnal (daily) variation in indicator density is observed in both inland and 

coastal waters. In general, when culture methods are used for FIB enumeration, the highest FIB 

densities are observed in the morning. Depending on the insolation on a given day and at a site, 

the lowest FIB density might occur between 2:00 p.m. and 3:00 p.m. These patterns suggest that 

early sampling might be more protective of public health when using culture methods. 

The density of the FIB as determined using qPCR is not as sensitive to time of day as the density 

measured using culture methods because the qPCR methods quantify DNA instead of 

metabolically active cells (Boehm et al. 2002; Converse et al. 2012). Furthermore, many 

epidemiological studies include data collected and pooled from throughout the day (Wade et al. 

2008). 

When sampling for qPCR quantitation, however, earlier sampling means that public notification 

will occur earlier in the day and therefore will inform the public in a timelier manner. 

Nevertheless, practical limitations (such as sample transport and other factors) could delay such 

notifications.

4.3.2.1.4 Sample Location

There is no standard definition of beach length, or a standard requirement for the distance 

between beach monitoring stations. Sampling locations should be selected on the basis of the 

ability of a small number of samples to adequately describe water quality at the site. These are 

generally locations where FIB are most likely to be associated with a fecal pollution source.

Sampling locations in the alongshore direction should be chosen on the basis of the mixing 

characteristic of the beach and location of sources of fecal contamination as determined by sanitary 

surveys. When there are beach features that influence hydrodynamics (mixing), beach regions with 

different hydrology cannot be expected to have similar FIB densities, and therefore they should be 

sampled separately. The following suggestions can also help in structuring a sampling plan:

• Sample within 60 meters of where the greatest beach use occurs (where the people are).

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

• If the beach is short, take samples at a point corresponding to each lifeguard chair, or one 

point for every 100 to 200 meters of beach, depending on the dimensions of the beach. 

• If the beach is long (more than 5 miles), take samples at the most highly used areas and 

spread out along the entire beach. 

• Sampling location should take into account beach features (e.g., channels, streams, 

jetties, groins, stormwater discharge pipes) that might affect FIB density.

Sampling locations should be selected to obtain the greatest amount of information that can be 

used for public health protection. The variable effect from a known or potential source would be 

an example of such useful information. In contrast, results from sampling at the discharge point 

of a source that always exhibits high indicator density would likely be less instructive.

4.3.2.1.5 Sample Depth

Taking a sample in an area parallel to the shore where the water depth is approximately knee 

deep or greater appears to offer some advantages. Indicator density tends to vary less in deeper 

waters than in shallower zones (USEPA 2005). The indicator density in shallower water is higher 

than that in deeper areas because of the re-suspension of indicator organisms growing or 

sheltered in sediments. Re-suspended indicators might not indicate fresh fecal pollution, and 

therefore samples with a high number of re-suspended organisms might not provide a good 

means to assess water quality. Other considerations, such as a steep beach face or safety

concerns, can also play a role in selecting the appropriate sample depth zone.

EPA’s general recommendation for all beaches has been that samples be taken at knee depth. 

However, local conditions will dictate the sampling depth selected for a beach. For instance, in 

high-energy environments, sampling is often conducted at ankle depth because it is safer and 

easier for the sampler. In California marine waters, for example, samples are taken at ankle depth 

in part to protect the safety of the sampler from the threat posed by incoming waves. In more 

quiescent waters, sampling can be conducted at up to waist depth. The data analysis conducted 

for the 2012 RWQC was based on the pooling of data from shin depth to waist depth (0.3–1.0 

meter) (Wade et al. 2010), which corresponds to the sampling depth in the NEEAR study, which 

was found to have high correlation with risk. The 2012 RWQC STVs and BAVs are based on the 

90th and 75th percentile, respectively, in shin- to waist-deep water.

qPCR results in shin-deep water were over 40 percent higher than those in waist-deep water (93 

versus 65 qPCR-CCE (calibrator cell equivalents)/100 mL, respectively) among NEEAR Great 

Lakes beaches (Wade et al. 2008). Differences were consistent throughout the day at Great Lakes 

beaches (unpublished EPA data). Differences between waist and shin depths were greater among 

marine beaches (320 versus 190 CCE) and tended to be greatest in the morning (unpublished 

EPA data).

The most important aspect of sample depth is consistency from sampling event to sampling event 

(Wymer 2007). Sampling at the same depth ensures the consistent representativeness of the 

sample. Therefore, EPA encourages states, tribes, and localities to sample at the same depth at a 

given beach to ensure consistency and comparability between sampling events. 

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The depth for the sample container (i.e., distance below the water surface) appears to be less 

critical than the depth zone (e.g., knee depth) where sampling is conducted (Le Fevre and Lewis 

2003). The depth below the water surface, however, should also be consistent. At waist to knee 

depth, this should be 0.5 to 1.0 foot below the water surface. At any depth more shallow than knee 

depth, mid-water column would be appropriate while avoiding introducing sand or sediment into 

the sample. A sampling depth of 0.3 meter below surface represents water to which swimmers 

receive maximum exposure with their faces under water. This was also the sampling depth used in 

NEEAR and other studies to establish risk relationships. However, variation in qPCR densities 

with respect to depth of sample collection has not been studied. An EMPACT (Environmental 

Monitoring for Public Access and Community Tracking) study (Wymer 2007) saw no consistent 

difference in colony forming units versus depth for culture methods. 

4.3.2.2 Sample Collection Techniques

Although EPA has no requirements for sample collection, adherence to specific, state-defined 

procedures for sampling is critically important for a successful beach monitoring program. This 

can be accomplished by implementing a detailed plan or written SOP for obtaining samples and 

submitting them for analysis. Proper collection, preservation, and storage of water samples are 

critical to ensuring the accuracy of the results of water quality analyses for FIB at swimming 

beaches, and to satisfy the QA/QC requirements of state certification programs. Section 4.3.3.2 

discusses the basic equipment and techniques that can be used to obtain water samples. 

Appropriate sampling procedures should be determined for a beach monitoring program on the 

basis of the sampling design, the availability of facilities and equipment, and how the samples 

will be processed. In addition, it is important to use consistent procedures and take careful notes 

in the field when collecting samples. Additional information about EPA-recommended SOPs for 

sample collection, handling, and subsequent analysis can be found in Standard Methods for the 

Examination of Water and Wastewater (APHA 1998).

4.3.2.3 Sampling after an Exceedance

When a water quality sample exceeds a beach notification threshold, a state must promptly issue 

a beach notification or resample if there is reason to doubt the accuracy, certainty, or 

representativeness of the first sample. This applies whether the method used to determine the 

exceedance was culture-based or qPCR-based.

• If a sample result is determined to be accurate and representative and exceeds a beach 

notification threshold, the state agency must issue a beach notification. The notification 

should remain in effect until resampling indicates that the beach notification threshold is 

no longer being exceeded and approved QA/QC requirements are being met. When the 

beach notification threshold is no longer being exceeded, the basic sampling approach 

may be resumed. If in the meantime heavy rainfall or other pollution events have 

occurred as listed below, refer to guidance for that instance.

• If there is reason to doubt the accuracy, certainty, or representativeness of the first sample 

collected, based on QA/QC measures, resampling should be considered. This might be the 

case if sampling results at the beach have shown that, historically, water quality has 

consistently met acceptable beach water quality thresholds and no known or potential 

sources of fecal contamination affect beach water quality. EPA recommends that additional 

samples be taken as soon as possible if the first sample exceeds water quality thresholds.

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If possible, the resampling should be completed immediately after detection of a beach 

notification threshold exceedance. If culture methods are used, the results should be obtained as 

expeditiously as sample collection and analysis can occur after the routine monitoring results 

indicate an exceedance. If qPCR is used, resampling results could be available later the same 

day. If the second sample indicates that a water quality threshold has been exceeded, the state or 

local government must promptly notify the public. 

Chapter 5 discusses notification procedures (beach advisories, postings, and closings) in more 

detail. BEACH Act grant QAPPs typically describe state training plans.

4.3.2.3.1 After a Sewage Spill or Pollution Event

For all beaches, EPA recommends sampling immediately after a sewage spill or other significant 

pollution event for which FIB densities might be expected to exceed standards. EPA also 

strongly recommends that beach managers consider a preemptive beach closure (with or without 

confirmatory sampling) when there is suspicion of a sewage spill or major leak. Chapter 5 

discusses beach closures in more detail. Beach or program managers should complete additional 

sampling of closed beaches to ensure mitigation of the spill before reopening the beaches. 

4.3.2.3.2 After an Advisory or Closing

After an exceedance, additional sampling should be conducted to determine whether a beach 

notification can be lifted. Because an advisory imposed on the basis of sampling results should 

not be lifted without subsequent sample results showing that the applicable WQS have been met, 

prompt resampling is preferable to waiting until receipt of the next routine sampling results. 

Beach advisories issued on the basis of the output of a predictive model can be lifted if the output 

from an additional model run estimates that water quality conditions have improved to within 

acceptable parameters or, alternatively, that the results of a water quality sample indicate that 

indicator densities once again meet the applicable standard. Section 5.2.1.2 discusses preemptive 

advisories in more detail.

4.3.2.3.3 After a Heavy Rainfall Event

EPA recommends that managers develop and follow a protocol for a variety of rain events and 

consider such protocols at all recreational beaches. Many states, tribes, and local governments 

have protocols in place. At beaches with stream and storm drain discharges, previous sampling 

has established that water quality is often poor after a substantial rain, justifying a preemptive 

advisory without confirmatory sampling results. A beach or program manager should consider 

local circumstances and evaluate whether additional monitoring or a formal protocol for 

preemptive beach notification advisories is appropriate. 

4.3.2.3.4 Other Circumstances

When routine monitoring at a sample location indicates elevated FIB densities, additional 

sampling can be done to determine the extent of the water quality problem. Defining the extent 

of the poor water quality more effectively protects public health and might provide valuable 

information for source identification and mitigation.

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4.3.3 Administering a Monitoring Program

4.3.3.1 Staffing Monitoring Programs

A monitoring plan should include an adequate staffing plan that accommodates periods of peak 

beach use. EPA recommends that professional staff from state and local agencies maintain 

primary responsibility for the design and oversight of beach monitoring. Citizen volunteers can 

also be used to perform supplemental beach monitoring program functions. For example, 

volunteers can be used to provide more intensive monitoring at high-priority beaches or to help 

with monitoring at low-priority beach areas where regular staff might not be available. 

Additional information on volunteer monitoring programs is available on EPA’s website at 

http://water.epa.gov/type/rsl/monitoring/index.cfm. 

Once the monitoring plan has been developed, the staff who will implement the program should 

receive training. Whether drawn from the ranks of professional staff, other municipal employees, 

or volunteers, the personnel responsible for sample collection and environmental measurements 

at the beach and those performing the bacterial indicator analyses should be trained for those 

activities. The quality of information produced by a monitoring program depends on the quality 

of the work done by field and laboratory staff. Separate training programs should be developed 

for field staff, laboratory staff, and others involved in the monitoring program. Laboratory 

training and analyst qualifications are generally evaluated as part of a laboratory accreditation 

program. The training for field staff should include a review of applicable SOPs, sampling 

locations, sampling equipment and containers, field forms and labels to be completed on-site 

(e.g., chain-of-custody forms, sample collection forms, sample labels), sample preservation 

information, personal protection equipment, coordination with the analytical laboratory, and 

important contact information. Follow-up training should continue for as long as the monitoring 

program is active. QAPPs should describe the content of training plans in BEACH Act grant 

QAPPs.

Early in each swimming season, it is advisable to conduct procedural reviews with each field 

sampling crew. Such reviews afford program oversight staff an opportunity to observe the 

techniques and procedures being used to collect samples, provide any necessary clarification, and 

immediately address any departures from program requirements. Reviews also evaluate whether 

program procedures are applicable to potentially changing conditions, and they offer an 

opportunity to solicit field staff opinions regarding procedure refinements or enhancements that 

could continue to improve the quality of the data. 

4.3.3.2 Field Sample Collection Methods

The monitoring plan should also include the following elements on field sample collection 

methods: 

• Selecting sampling locations (e.g., maps, names of sampling locations). The beach 

manager should survey the site to become familiar with its physical and hydrologic 

features, in addition to or as part of a sanitary survey. The reconnaissance site visits 

should include collecting the following information: 

– Most convenient and safest point of access to the site. 

– Potential sampling locations.

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– Necessary equipment.

– Directions to sampling locations relative to access point.

– Justification for the selection of each sampling location. 

– Other information necessary for preparing for sampling at a site (e.g., health and 

safety requirements).

• Chain-of-custody forms, field forms, bottle labels. A sampler should record a detailed 

description of each sample collected and record it on a chain-of-custody form. The form 

should document the sampling location (site ID), time of collection, date of collection, 

collector’s name and signature, agency, laboratory to which the samples were delivered 

or sent, and other notes or comments. Field sampling staff should document on a field 

form basic on-site measurements and observations, such as weather conditions, general 

characteristics about the water, time of sample collection, name of sampler, and number 

of sample bottles filled. A field log (notebook) can also be used to record observations 

and notes not recorded on the field forms. 

A sample identification label (to be placed on the sample container) should be completed 

to accompany each sample throughout the chain of custody. The label should document 

the information for each sample, including sampling trip number, sample number, analyte 

for analysis, and date of sample. All entries should be made in indelible ink and coincide 

with sample information on the field form and chain-of-custody form. 

• Equipment, sample container needs. Sampling for recent EPA epidemiological studies 

was conducted consistent with recommendations on microbiological sampling in 

Standard Methods for the Examination of Water and Wastewater (Clesceri et al. 1998). 

Those studies used capped 1,000-mL, pre-sterilized polypropylene bottles for sample 

collection. EPA, in its Microbiological Methods for Monitoring the Environment, Water 

and Wastes (USEPA 1978), suggests wide-mouth borosilicate glass bottles with screw 

caps or ground-glass stoppers; however, glass bottles can break, causing loss of the 

sample. Polysulfone (Nalgene) containers of appropriate size are also used. Heat-resistant 

polypropylene bottles may be used if they can be sterilized without producing toxic 

materials when autoclaved, or pre-sterilized disposable containers may be employed. 

Sufficient coolers and ice should be available to place samples promptly on ice for 

transport to the laboratory. Other equipment needs will vary according to local sampling 

practices and/or state protocols.

• For qPCR use, pre-sterilized, single-service plastic containers are optimal because of the 

potential for DNA fragments to persist after sterilization. Otherwise, if used, reusable 

containers should be constructed of polysulfone or other similar plastic material, soaked 

in 5 percent bleach solution, and then rinsed with distilled water before each use. 

• Health and safety concerns. Any field team member who participates in sample 

collection at the beach should know how to swim. Sample collection should be postponed 

if conditions are dangerous (e.g., bad weather, rough water). 

• Laboratory availability and scheduling of sample deliveries. Samples are usually 

transported to the laboratory by the person collecting the sample or picked up by 

laboratory personnel. Because of holding time limitations, the laboratory should be 

conveniently near the sampling site and notified a few days before the sampling effort so 

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that it is prepared to process the samples promptly. Chain-of-custody procedures should 

be followed at the laboratory for all samples.

• Communication with the lab. Open communication and collaboration with your 

laboratory service provider will greatly benefit your monitoring program. Laboratories 

work with a variety of clients from various backgrounds and with different levels of 

experience. Laboratories also routinely provide sampling kits (bottleware, labels, and 

custody records), assist in training sampling staff, and provide additional sampling 

instructions or responses to frequently asked questions about their bottleware. When 

selecting a laboratory, if multiple laboratory service providers are available in the vicinity 

of the beach, consider value-added services. In addition to the services above, many 

laboratories offer courier services to drop off supplies and pick up samples, and some 

provide preprinted chain-of-custody forms and bottle labels that require only the 

samplers’ initials and the date and time of sample collection.

4.3.3.3 Managing Data

One of the most important aspects of a monitoring program is data management, from the 

collection process through the data analysis. Data management activities include documenting 

the nature of the data and subsequent analyses so that the data from different sites are 

comparable. Data management also includes handling and storing both hard copies and 

electronic files containing field and laboratory data. It is important to understand and comply 

with all state agency policies and standards regarding data collection and generation. 

The operation of the data management system should include QA oversight and QC procedures. 

If changes in hardware or software become necessary, the data manager should obtain the most 

appropriate equipment and test it to verify that the equipment can perform the necessary jobs. 

Appropriate user instructions and system documentation should be available to all staff using the 

database system. Developing spreadsheet, database, and other software applications involves 

performing QC reviews of input data to ensure the validity of computed data. 

EPA requires beach managers to add their monitoring data to the Agency’s STORage and 

RETrieval (STORET) database at http://www.epa.gov/storet/wqx/index.html. Each sampling 

result in STORET is accompanied by information describing where the sample was taken 

(latitude, longitude, state, county, hydrologic unit code, and brief site identification); when the 

sample was gathered; the medium sampled; and the name of the organization that sponsored the 

monitoring. Additional information on STORET is available at http://www.epa.gov/storet. 

States, tribes, and local governments can submit their data using a database provided by the 

beach program, create a state or local STORET database, or create an alternative data system. 

The beach program’s monitoring database can be accessed at 

http://water.epa.gov/grants_funding/beachgrants/datausers_index.cfm#monitor. These databases 

submit monitoring data to EPA’s Water Quality eXchange (WQX), which accumulates data that 

are copied into the STORET repository on a weekly cycle. Staff working with the database 

should have expertise and training in the software and in the procedures for data transport, file 

transfer, and system maintenance.

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4.3.3.4 Program Implementation and Oversight

States and tribes should regularly assess the effectiveness of their monitoring programs. The 

purpose of assessments (such as surveillance, readiness reviews, technical system audits, 

performance evaluations, and audits of data quality) is to determine whether the established QC 

procedures are being used and how the program is operating. Checklists or reviews of program 

documentation and reports can be used to evaluate different aspects of the program. The types 

and number of assessments to be performed can be documented in the monitoring program 

oversight plan. In addition, the program should clearly provide for the authority of the assessor 

(e.g., a QA officer) to stop work and should identify under what conditions that might occur. 

The QA program should include procedures for identifying and defining a problem, assigning 

responsibility for investigating the problem, determining the cause of the problem, assigning 

responsibility for implementing corrective action, and assigning responsibility for determining 

the effectiveness of the corrective action and verifying that the corrective action has eliminated 

the problem. Supervision is important during the program. To provide advice and identify 

problems when they occur, personnel providing oversight to technical staff should be wellversed in the procedures they are performing. Such proficiency is needed whether in the field 

performing the sampling or in the laboratory performing the microbiological analyses.

4.3.3.5 Public Comment

Public review of the monitoring plan is part of the overall public review and comment criterion 

described in section 2.2.11 (performance criterion 11). States or local governments must submit 

documentation of the public review to EPA. 

4.4 Methods and Assessment Procedures (Performance Criterion 3) 

Performance criterion 3 requires the states and tribes to document methods and assessment 

procedures. States and tribes must:

• Submit to EPA methods for characterizing water quality relative to human health in 

coastal recreation areas.

• Provide documentation of the performance of methods other than those that EPA 

approved or validated.

• Identify and submit to EPA assessment procedures for identifying short-term increases in 

FIB densities that indicate risk to human health in coastal recreation waters.

4.4.1 EPA-Approved or Validated Analytical Methods

EPA recommends a number of analytical methods for use in testing recreational waters. These 

are methods that EPA has approved and codified at 40 CFR part 136 or validated in single- or 

multi-lab validation studies. These methods, with their associated indicators, are used to 

determine whether the water quality at a beach exceeds or is likely to exceed the applicable 

WQS. EPA has established relationships through epidemiological studies between FIB density in 

the water and levels of illness.

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Sections 4.4.1.1 and 4.4.1.2 discuss EPA’s approved culture and validated qPCR methods. 

Section 4.4.2 provides information on selecting the appropriate analytical method—culture 

(4.4.2.1) or qPCR (4.4.2.2). Subsections of 4.4.2.2 discuss the analysis of site-specific 

performance that EPA encourages for qPCR methods. 

4.4.1.1 Culture Methods

In July 2003 EPA promulgated testing procedures in Guidelines Establishing Test Procedures 

for the Analysis of Pollutants; Analytical Methods for Biological Pollutants in Ambient Water; 

Final Rule (Office of the Federal Register 2003). The 2003 rule revises 40 CFR part 136 to add 

analytical methods for Escherichia coli, enterococci, Cryptosporidium, and Giardia in ambient 

waters. It includes methods published in the Official Methods of Analysis of AOAC International 

(AOAC International 1995), the 20th edition of Standard Methods for the Examination of Water 

and Wastewater (APHA 1998), and the 2000 edition of the Annual Book of ASTM Standards

(volumes 11.01 and 11.02; ASTM 2000). It also includes methods developed by EPA and 

commercial vendors, including Hach Company, IDEXX Laboratories, and others. This ruling 

was updated in a final ruling in March 2012, which provided updated versions of EPA methods 

(see FR [Federal Register] 77(97):29758). 

For beach testing, EPA recommends that states and tribes use the EPA-recommended culture 

methods mentioned above. The methods identified at 40 CFR part 136 are also acceptable. States 

and tribes that want to use culture methods other than the currently approved methods at 40 CFR 

part 136 must go through EPA’s Alternate Test Procedure (ATP) program, which requires 

submission of their method, along with validation data, to EPA. To meet performance criterion 3, 

documentation supporting the validity of methods other than those EPA has approved must be 

provided. Detailed descriptions of culture methods are included in 

http://water.epa.gov/scitech/methods/cwa/methods_index.cfm. Vendor method descriptions can 

be obtained from the various vendor websites (see FR 77(97):29758 for details). 

4.4.1.2 qPCR Methods

EPA Methods 1611 (USEPA 2012a) and 1609 are EPA-validated qPCR Enterococcus spp. 

methods (see http://water.epa.gov/scitech/methods/cwa/bioindicators/upload/Method-1611-

Enterococci-in-Water-by-TaqMan-Quantitative-Polymerase-Chain-Reaction-qPCR-Assay.pdf). 

Method 1609 has internal amplification control (IAC). EPA expects to validate qPCR methods 

for E. coli and Bacteroidales in the near future. Because at present only culture methods are 

included at 40 CFR part 136 as approved methods, the ATP protocol may not be used to qualify 

these qPCR methods for adoption into state or tribal WQS or for use in beach monitoring. 

Consistent with the 2012 RWQC, EPA encourages states and tribes that want to use EPAvalidated qPCR methods to conduct a site-specific analysis of the method’s performance before

use in a beach notification program or adoption of WQS based on the method. Documentation of 

the site-specific analysis has two parts: method performance (4.4.2.3.1) and site-specific 

acceptability (4.4.2.3.2). In addition, section 4.4.2.3.3 discusses logistical and other practical 

considerations for implementing a qPCR method. 

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4.4.2 Selection of Analytical Methods: Culture versus qPCR

4.4.2.1 Culture Methods

Analyzing water samples for the enumeration of FIB by culture methods such as membrane 

filtration, multiple-tube fermentation, or defined substrate technology has been the standard for 

decades. Although refined, the culture methods in use today still require bacterial growth in 

specific selective media for quantification. Culture methods require at least 18 to 48 hours to 

produce results, with the densities of the target organism reported in colony-forming units (CFU) 

or most probable number (MPN) per 100 mL. Previous research (e.g., Boehm 2007; Griffith et 

al. 2007; Noble et al. 2003; Taggart et al. 1992) has shown that FIB density exhibits a high 

degree of methodological and temporal variability. Culture results, nevertheless, are economical 

and reproducible, and they can serve as a source of information for managing waters and 

developing predictive models (section 4.5) to provide timely estimates of FIB density. 

Culture results are also effective in characterizing long-term water quality and variability at 

beaches. If, over the course of a season, weekly water quality monitoring fails to identify any 

occasions when the WQS were exceeded, it can be assumed that water quality is generally good. 

That can be expressed numerically by calculating a GM of the results or, more simply, by 

reviewing the number of exceedances or viewing data displayed graphically. Such results might 

suggest a reduced monitoring frequency at that location. Conversely, if weekly culture results 

produce a range of values including WQS exceedances, the results would indicate that sources of 

contamination exist, that the water quality is variable, and that conducting more intensive 

monitoring—or using a predictive model or qPCR analytical methods for more timely public 

notification—might be appropriate for the site.

4.4.2.2 qPCR Methods

Determining water quality by quantifying the DNA of FIB is a well-established methodology 

(e.g., Haugland et al. 2005, Noble et al. 2010). Unlike culture-based methods, qPCR methods 

quantify all forms of FIB, whether viable cells, injured cells not capable of growing on selective 

culture media, dead cells, or fragments of free DNA. The premise is that like the viable cells, the 

molecular material indicates the presence of fecal material from humans or other vertebrates and 

an associated risk of illness, likely from human enteric viruses also found in sewage and 

wastewater treatment plant effluent (Colford et al. 2012; Wade et al. 2008). Results of the 

epidemiological studies conducted for the 2012 RWQC demonstrated a significant association 

between gastrointestinal illness in swimmers and both culture and qPCR enumeration methods 

for Enterococcus; the association observed with qPCR enumeration was the stronger of the two. 

The 2012 RWQC discuss using EPA’s qPCR Enterococcus spp. method (Method 1611) as a tool 

for beach management and potential inclusion in WQS. The primary advantage of qPCR 

methods compared to culture methods is that analytical results can be available in as few as three

hours after receipt of the sample in the lab. This means that the qPCR results are much more 

likely to reflect water quality on the day when recreators are exposed to the water that was 

sampled. However, using a qPCR method might pose challenges for the beach or program 

manager, including method performance, site-specific acceptability, and practical considerations. 

Before deciding to use qPCR methods at local beaches, a beach manager should assess the 

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acceptability and feasibility of applying qPCR methods in light of these potential challenges. 

Section 4.4.2.3 discusses this in more detail. 

4.4.2.3 Assessing the Use of qPCR on a Site-specific Basis

A primary message of this document is that beach and program managers should develop tiered 

monitoring plans that reflect beach-specific use and risk. The decision whether to use qPCRbased methods will require weighing the potential advantages of more timely public notification 

against the site-specific characteristics of the beach and resource and logistical constraints. This 

analysis will help a beach or program manager determine whether using a qPCR-based method is 

feasible for local waters before investing in capital equipment and ancillary supplies, repurposing 

lab space, and providing the method-specific staff training required to implement qPCR for 

beach water quality analyses.

The 2012 RWQC recommend criteria for Enterococcus or E. coli as measured by culture 

methods. Although the 2012 RWQC recognize the value of qPCR for beach monitoring, the 

RWQC only provided supplementary information on qPCR and did not base EPA’s national 

RWQC recommendation on it given EPA’s limited knowledge regarding the performance of 

qPCR methods under varied water body conditions. EPA encourages state and tribal beach 

programs that want to use qPCR as a method for beach monitoring to conduct a site-specific 

analysis of the method’s performance and to assess the method’s site-specific acceptability 

before using it in a beach notification program or adopting WQS based on the method. These 

two assessments are described below.

4.4.2.3.1 Assessing Site-specific Method Performance

States and tribes undertake beach water quality sampling to identify WQS exceedances to issue 

beach advisories or closures. As discussed in the 2012 RWQC, the state of knowledge regarding 

the performance of qPCR methods under varied water body conditions is limited. EPA Methods 

1611 (USEPA 2012a) and 1609 (USEPA 2013b) are two EPA-validated qPCR enterococci 

methods. Method 1611 was released simultaneously with the RWQC. Method 1609 is an 

improved version of Method 1611. It uses a newer formulation of PCR reagent (environmental 

master mix) that has shown enhanced inhibition control compared to the reagent used in Method 

1611 (universal master mix). In addition, Method 1609 includes a competitive IAC assay (i.e., a 

control for inhibition) to help specifically identify false negative reactions (i.e., test results that 

wrongly show an effect to be absent) or reduced amplification efficiency due to Taq DNA 

polymerase inhibition (Haughland et al. 2012). Although either method is acceptable for use, 

EPA recommends using Method 1609 because of these enhancements. 

Both Method 1611 and Method 1609 quantify the number of copies of Enterococcus DNA in 

surface water. For states and tribes interested in using either method to make site-specific beach 

notification decisions, the 2012 RWQC provide qPCR-based beach notification thresholds. If 

local beach managers are considering using EPA Method 1611 or 1609, the method 

documentation (USEPA 2012a; USEPA 2013b) provides information on identifying method 

limitations in specific waters, such as interference, and procedures for correcting method 

problems. 

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The performance acceptability criteria of EPA Method 1609 or 1611 are stated in the method 

document. The acceptability criteria are based on a nationwide validation of the method (see 

section 14 in Methods 1609 and 1611). The method document assumes that the testing laboratory 

has been able to perform the method within the acceptance criteria and that the beach or program 

manager wants to determine whether the method would be acceptable for use at a particular site.

4.4.2.3.2 Assessing Site-specific Acceptability

The analysis for site-specific acceptability of qPCR analysis should include the following 

elements, which are more fully described in Acceptability of the EPA qPCR Test at Your Beach 

(USEPA 2013a): 

• At least 10 samples should be taken on different days for site evaluation before using the 

method for beach notification decisions. Sampling for a longer period, however, will 

provide data that are more representative. Among these samples, a maximum of 10 

percent can fail the Salmon DNA sample processing control (SPC) assay criterion (see 

section 9.12 in Method 1611) or the SPC and IAC assay criteria (see sections 9.12 and 

9.13 in Method 1609). For any samples that fail the initial analysis, one or both of the 

interference mitigation approaches—extract dilution (see section 9.12 in Methods 1609 

and 1611) or higher Salmon DNA (see reference 17.5 in Method 1609)—can be used to 

assess for mitigation of the interference. If mitigation by one of these approaches is 

successful (i.e., samples now pass the control assay criteria specified above), these 

samples can be considered as not having failed in the site evaluation. 

• Particularly if beach advisories or closures are not mandated by local standards after a 

heavy rain event, site evaluation sampling should include a representative number of 

samples collected after such events.

• Sites should be reevaluated every year, preferably before using the method for beach 

action decisions, because water characteristics, including the appearance and 

disappearance of inhibitors to the method, have been shown to change over time. 

Some localities might be inclined to compare the frequency of beach advisories based on the 

qPCR test versus the culture test. EPA neither encourages nor discourages such comparisons; 

however, if used, the results should be interpreted carefully. Comparisons between exceedances 

do not reflect their respective method performance when all the controls in the methods are 

performing properly. In addition, a higher rate of exceedances does not necessarily reflect greater 

health protection when evaluating qPCR and culture approaches because such comparisons do 

not take into account the relative severity of the total health risks on the days of exceedance. In 

all cases, however, the same-day notification potential for qPCR more accurately reflects water 

quality for beachgoers compared with methods where results are not available until the following 

day.

4.4.2.3.3 Logistical and Other Practical Considerations

Although the results from qPCR sampling can be obtained in a few hours, a number of factors 

can affect a state’s or tribe’s ability to deliver same-day notification. Besides having a laboratory 

that is close enough to the beach to allow samples to be quickly transported, prepared, and 

analyzed, beach or program managers should consider cost, configuring laboratory facilities for 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

qPCR use, choosing an appropriate 

instrument, providing adequate staff 

training, selecting reagents and controls, 

and documenting QA/QC protocols. 

The Southern California Coastal Water 

Research Project (SCCWRP) conducted a 

pilot study in which the participating 

jurisdictions used qPCR to make health 

protection decisions at nine beaches in 

Orange County (Griffith and Weisberg 

2011). The authors determined on the 

basis of the study results that cost and 

temporal logistics are the biggest 

challenges to initial use of rapid methods, 

and that would likely limit qPCR initially 

to heavily used beaches or those with 

highly variable water quality. They also 

found that to post notifications by noon, 

they needed to modify every step in the 

process, from sample collection to posting 

advisories. See the text box for more 

details.

Southern California Coastal Water Research 

Project (SCCWRP) Pilot Study

During their pilot study, SCCWRP found they had to 

modify every step—from sampling to posting 

signs—to provide notifications by noon. The 

modifications included:

• Sample collection routine.

- Started sampling earlier in the morning.

- Limited sites sampled to high-priority

beaches (i.e., heavily used or with highly 

variable water quality).

- Used a second crew for qPCR sites.

• Laboratory procedures.

- Used a faster method (i.e., one with a

shorter cycling time).

- Did not use a DNA extraction kit with 

multiple pipetting steps.

- Completed all preparation steps before 

samples arrived at the lab.

• Communication with the beach manager.

- Automated the data analysis and QA using

Excel macros.

- Used electronic signs that could be 

controlled remotely.

4.4.3 Using Other Methods or Indicators for Developing Site-specific WQS

Previous sections of this document discuss using EPA-approved culture methods or validated 

qPCR methods for assessing water quality at recreational beaches. Relationships have been 

established through epidemiological studies between the density of FIB in the water measured by 

these methods and levels of illness. There are three scenarios states and tribes might present; they 

are discussed briefly below. 

• The state or tribe wants to use a method that is not EPA-approved or validated but has

a predictable and consistent relationship with an approved or validated EPA method.

The state or tribe should consult Site-Specific Alternative Criteria Technical Support

Materials for Alternative Indicators and Methods (in press-c). In this case, the

relationship between the alternative method and the EPA method can be correlated with

the illness rates associated with the EPA method and used to establish site-specific

alternative water quality criteria to be adopted into site-specific WQS based on the

alternative method.

• The state or tribe wants to use an approved and validated EPA method and wants to

account for local-scale, non-human sources of fecal contamination. The health studies

that substantially informed EPA’s 2012 RWQC recommendations were conducted at

beaches contaminated by secondary treated and disinfected wastewater effluent. Beaches

affected by other fecal sources could pose different, potentially much lower, human

health risks at the same level of water quality recommended in the 2012 RWQC. In this

instance, a state or tribe would use QMRA to estimate the human health risks posed by

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the pathogens coming from the specific sources of fecal contamination affecting a site 

and to calculate site-specific water quality criteria that would provide a level of public 

health protection equivalent to the health goals discussed in the 2012 RWQC. Once 

adopted into site-specific WQS, these criteria would provide a basis for identifying beach 

notification thresholds. States and tribes wishing to establish site-specific water quality 

criteria accounting for nonhuman sources of fecal contamination should consult SiteSpecific Alternative Criteria Technical Support Materials for Alternative Fecal Sources

(USEPA in press-b).

• The state or tribe wants to use a method that does not have a predictable and consistent 

relationship with an approved or validated EPA method but is demonstrated to be 

associated with health. In this instance, the state or tribe would establish a site-specific 

health relationship between the indicator and human health effects at the site by 

performing a scientifically defensible epidemiological study and/or QMRA at the site. 

The documented association between the indicator and health would serve as the basis for 

site-specific criteria to be adopted into site-specific WQS. These WQS would provide a 

basis for identifying beach notification thresholds in the waters where the relationship 

was established. States and tribes wishing to establish a site-specific health/indicator 

relationship should consult Alternative Health Relationships Technical Support Materials

(USEPA in press-a).

4.5 Monitoring Report Submission (Performance Criterion 4)

The fourth performance criterion requires development of mechanisms to collect relevant 

monitoring information, provide timely communication of water quality to the public, and submit 

reports to EPA. 

States and tribes must report their monitoring data to the public in a timely manner, including 

posting the data on a publicly available website. A publicly available website is one that:

• Has its address included on grantee websites and in published materials (e.g., news 

releases, advisories, beach program documents) as a source of additional information 

about the state’s or tribe’s beach program. 

• May be a dedicated beach water quality website or a general state or tribal news website. 

• Is reliably operational, at least during the beach season. 

• Does not require access credentials. 

Posting all monitoring data to EPA’s STORET would also meet the requirement for a publicly 

available website. If a state or tribe uses STORET as its “publicly available website,” related 

state or tribal websites must include a link to STORET and an explanation of the type of data 

posted. 

In this context, “timely” means posting monitoring data associated with an exceedance 

concurrently with or shortly after the issuance of a notification action. States and tribes must 

report all other monitoring data to EPA’s STORET and to their publicly available website, if not 

STORET, at least annually or at a frequency the EPA Administrator requires. Reported 

monitoring data must be consistent with section 4.3.3.3. 

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4.5.1 Data Validation and Verification Recommendations

EPA recommends that managers use procedures to verify whether the microbiological sample 

collection and analyses have correctly estimated the densities of indicator bacteria, to ascertain 

whether requirements for a specified use of the results have been fulfilled, and to determine how 

the data should be interpreted for decision making. This section discusses some of the important 

aspects of such procedures. These should be included in the monitoring program design to ensure 

that the data obtained are usable and defensible. Several iterations through these procedures 

might be necessary to ensure that the data and their interpretation are correct.

4.5.1.1 Data Validation Methods

Single laboratory validation refers to the confirmation that data quality objectives (DQOs) for a 

specified intended use have been fulfilled. Thus, once beach or program managers have 

confirmed that the data meet standards and contract requirements, they can systematically 

examine the data to determine the technical usability with respect to the planned objectives. This 

activity can also provide a level of overall confidence in reporting the data on the basis of the 

methods used. For example, if the wrong medium was used or the incubation temperature limit 

was exceeded, managers would assign a qualifier to the data indicating their uncertainty and 

reject the data from further analyses. The managers should then prepare a report that provides an 

assessment of the usability of the data, a summary of environmental sample results, and a 

summary of QC and QA results. The report should discuss any discrepancies between the DQOs 

and the data collected and any effects such discrepancies might have on the ability to meet the 

DQOs.

Finally, managers should assess the data to evaluate whether they are of the right type, quality, 

and quantity to support their intended use. The assessment could include reviewing the DQOs 

and sampling design, conducting a preliminary data review, selecting the statistical test, 

verifying the assumptions of the statistical test, and drawing conclusions from the data.

4.5.1.2 Data Verification Methods

The laboratory service provider should provide the procedures for verifying whether the bacterial 

indicators were correctly determined for any method used. Verification involves performing 

additional tests to identify those colonies found on the membrane filter that provided 

information. A false positive rate is calculated as the percent of colonies that reacted (were 

identified as the indicator) but were not actually the indicator. A false negative rate is calculated 

as the percent of colonies that did not react as anticipated (and so were not identified as the 

indicator) but were in fact that indicator. False positive and false negative rates for the media 

used in EPA Methods 1600 (USEPA 2009a) and 1603 (USEPA 2009b) are provided in those 

methods. Verification procedures should be used in establishing QC limits on initial use of the 

procedure, when using a new technician to perform the procedure to ensure that method 

requirements can be met, whenever any changes are made in how the procedure is performed or 

in the materials used in the procedure, and always when the results are to be used in evidence for 

legal proceedings.

The laboratory service provider should review the sample records, chain-of-custody records, and 

sample tracking records to verify that all the samples collected were analyzed so that the data set 

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will be complete. It should also verify data entries and analyses and, for large quantities of data, 

perform spot-checking to detect potential data entry errors. Additional checks could include 

graphically displaying data to visually inspect for potential errors, using statistical methods to 

detect invalid data, and checking for duplicate data entries. Input data should be reviewed for 

accuracy, bias, completeness, precision, representativeness, and uncertainty. In addition, the data 

reductions and transformations should be reviewed (audited) to ensure that they have been 

correctly performed. The calculation review could include rechecking the computations, 

reviewing the assumptions used and the selection of input data, and checking the input data 

against the original sources to be sure there are no transcription errors. The EPA methods 

provide the types of calculations that might be performed on bacterial indicator filter counts to 

estimate bacterial densities per sample. Standard Operating Procedure for Recreational Water 

Collection and Analysis of E. coli in Streams, Rivers, Lakes and Wastewater (IITF 1999) 

provides more examples. 

Beach program managers should obtain a report from the laboratory service provider 

documenting the results of the data verification. To verify conformance of the data collection 

effort with the plan, data should pass the specified numerical QC tests (precision and bias limits); 

the plans should be followed and calculations should be performed correctly; all samples should 

be treated consistently; and the necessary quantity of data and information relative to the stated 

DQOs should be obtained (completeness). Staff should address data concerns, if possible, or 

managers should reject the data and not use them to make the decision. 

4.6 Use of Predictive Tools in Beach Monitoring Programs

EPA encourages states and tribes to use predictive tools to make timely beach notification 

decisions and to deliver same-day notifications. Although using qPCR can provide results sooner 

than using culture methods, qPCR might not be a viable option for all settings. To reduce 

exposure to pathogens, agencies operating beach monitoring and notification programs need 

tools that can provide a quick, reliable indication of the water quality conditions. Predictive 

models and other predictive tools are another means to provide rapid estimates. These tools are 

used to supplement, not replace, monitoring; they provide timely estimates when a lag time 

exists between performing sampling and obtaining results.

Predictive tools might also be useful in developing or adapting routine monitoring programs to 

focus efforts when conditions favor high FIB levels. The predictive tools examined in Predictive 

Tools for Beach Notification, volume 1 (USEPA 2010b) include statistical models, rain threshold 

levels, notification protocols, and deterministic models. Information from that report is briefly 

summarized below. The report is available on EPA’s website at 

http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P26-ReportVolume-I-Final_508.pdf. 

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Significant development and implementation 

of statistically based models have occurred 

recently, especially in the Great Lakes (Lake 

Erie and Lake Michigan), where many 

predictive tools were proven reliable and 

cost-effective (Francy 2009; Nevers and 

Whitman 2005). EPA believes such 

predictive tools could be applicable in many 

other settings as well, including marine and 

inland beaches. These tools develop 

statistical relationships or models between 

FIB densities (dependent variables) and 

various observations that describe the 

environmental conditions at the beach 

(independent variables). The models use 

recent and historical FIB densities and 

independent variables that include other 

water quality, hydrodynamic, and 

meteorological data to predict current FIB 

levels and to forecast near-future FIB levels 

or the likelihood of exceeding a WQS. 

Statistical models and other predictive tools 

can be run as frequently as data are available 

for measured independent variables and as 

long as models are producing reliable 

predictions that protect public health. 

Rainfall-based beach notifications have been 

widely used at marine and freshwater 

beaches for decades. Rainfall-based beach 

notification thresholds are issued at some 

beaches on the basis of an analysis of 

historical data. At such beaches, it has been 

shown that after a certain amount of rainfall, a beach is likely to have high FIB densities 

(USEPA 1999). Similar notification protocols could be developed in which a certain 

combination of conditions has been shown to result in high FIB levels. 

Information on these and other types of predictive tools is provided below. 

Chicago’s Modeling Project

The Chicago Park District (CPD) has developed 

predictive models for water quality to provide 

more current and accurate information to the 

public. 

CPD selected five public beaches in Chicago for 

modeling, from the largest in size (Montrose 

Beach) to one of the city’s most popular (Oak 

Street Beach). 

All the beaches are primarily affected by 

nonpoint sources and have a history of between 

8 and 15 percent exceedance rates (percent of 

days when the mean of two samples exceeds 

235 CFU E. coli per 100 mL of water). 

USGS helped CPD develop empirical models 

using multivariate regression. They modeled 

E. coli levels using results from both the current 

culture-based method and a qPCR-based 

method.

CPD initially anticipated the need for two years 

of data to have working models developed 

because results depend strongly on the weather. 

The Chicago area has very different beach 

seasons from year to year; therefore, a larger 

data set would help improve the model’s 

accuracy. 

CPD began using the model in 2012 to make 

management decisions about notification 

actions. They monitor all beaches every 

weekday. CPD runs the models at 9:00 a.m. and 

issues advisories by 9:30 a.m. If the model 

shows no exceedance, CPD posts a green flag; 

however, the public can view both model results 

and sampling values by visiting the beach, 

viewing the website, or calling a hotline.

4.6.1 Statistical Models

Statistical model is a general term for any type of statistical modeling approach that predicts or 

forecasts beach water quality. Statistical models are also called statistically based models and 

include most predictive models currently in use. Linear regression models assume a linear 

relationship between factors, or combinations of factors, and FIB densities (Boehm et al. 2007; 

Nevers and Whitman 2005; Olyphant and Whitman 2004; USEPA 2007). The most highly 

developed and currently used statistical modeling approaches for beach water quality 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

management are multivariable linear regression models. These types of models couple 

combinations of important independent variables to FIB densities. The most common model 

outputs are estimated FIB levels or a probability of exceedance of the adopted state WQS for 

FIB. Typical, easy-to-measure environmental and water quality variables that are predictive of 

FIB density can include:

• Meteorological conditions (e.g., solar radiation, air temperature, precipitation, wind speed 

and direction, dew point). 

• Water quality (turbidity, pH, conductivity/salinity, ultraviolet/visible spectra).

• Hydrodynamic conditions (freshwater discharge, magnitude and direction of water 

currents, wave height, tidal stage).

• Other factors such as presence and number of birds or people. 

Statistical models are especially useful at some beaches and less useful at others. According to 

Francy (2006), statistically based modeling can effectively predict water quality in situations 

where nonpoint or unidentified sources dominate and in settings where discrete sources have 

been identified (Nevers and Whitman 2005). If a beach rarely has high bacteria densities or, 

conversely, chronically exceeds a bacterial WQS, it is unlikely that a statistical predictive model 

would significantly improve timely decision making and notification. If a beach occasionally 

exceeds the WQS or if bacteria levels are highly variable, statistical models can help by 

providing a timely prediction of whether FIB are likely to exceed the WQS according to 

parameters that are easier and faster to measure than FIB densities.

Developing and using a statistical predictive model is a dynamic process based on data collected 

from beach monitoring. Statistical modeling uses a retrospective correlation of measured water 

quality (FIB levels) with conditions observed at the time of sample collection to produce a timely 

estimate of water quality for recreational water management and use by the public. Model 

developers can create Internet-based systems that provide model predictions (similar to weather 

forecasts) to the public for the current period, as compared to other Internet-based systems that 

alert the public to exposure that might have occurred a day or two earlier. However, models 

require periodic validation and refinement to improve predictions. 

EPA has developed a very effective tool for building freshwater statistical models—Virtual 

Beach. Virtual Beach is a versatile and user-friendly statistical tool that links past water quality 

data to observed variables to produce real-time estimates of water quality at freshwater beaches 

(USEPA 2010a). EPA is expanding Virtual Beach for marine beaches. Visit 

http://www2.epa.gov/exposure-assessment-models/virtual-beach-vb for more information. 

Although USGS, the National Oceanic and Atmospheric Administration (NOAA), and other 

agencies and Internet sources are available to provide much of the data necessary for developing 

multivariable linear regression models, many modeling efforts have been shown to be sitespecific. Therefore, beach water quality managers can expect to need to analyze their own 

historical FIB data in relation to mined data from other agencies to develop models specific to 

their own locations. To make this process simpler, there is a newly available version of Virtual 

Beach, V.3.0. 

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Other useful references for information on statistical models include Predictive Modeling at 

Beaches, volume 2 (USEPA 2010a), Temporal Synchronization Analysis for Improving 

Regression Modeling of Fecal Indicator Bacteria Levels (Cyterski et al. 2012), Partial Least 

Squares for Efficient Models of Fecal Indicator Bacteria on Great Lakes Beaches (Brooks et al. 

2013), and Application of Empirical Predictive Modeling Using Conventional and Alternative 

Fecal Indicator Bacteria in Eastern North Carolina Waters (Gonzalez et al. 2012). 

4.6.2 Rainfall-based Beach Notification Threshold

The objective of a rain threshold level is to identify the level of rainfall at which FIB levels are 

likely to trigger a beach notification. That is achieved if a statistical relationship—a simple 

regression or a frequency of exceedance analysis—between rainfall amount, intensity, and 

duration and FIB densities can be observed or if a level of rainfall and rainfall conditions is 

consistently shown to be associated with increased FIB densities. With that information, many 

beach managers and public health officials commonly issue a preemptive rain threshold advisory 

after a rain event of a predefined intensity or duration. Beachgoers are familiar with routine, wetweather closures in locations where they are implemented. The beach notification threshold can 

then serve as a management tool for developing notification protocols or predicting WQS

exceedances that require a beach notification. 

4.6.3 Notification Protocols

Notification protocols are based on a set of decision criteria that trigger beach notifications in 

anticipation of poor water quality or other potentially hazardous conditions (e.g., rough waves, 

strong rip currents, red tide). The protocol can rely on sampling results, other information, or 

beach characteristics either alone or in addition to sampling results. Such evaluations are 

designed to supplement bacteria data with characteristics of the beach that can influence the 

related bacteria levels (e.g., proximity to pollution sources, stormwater runoff, current, or wind 

direction). 

4.6.4 Deterministic Models

Deterministic models use mathematical representations of the processes that affect FIB densities 

to predict exceedances of WQS. They include a range of simple to complex modeling 

techniques, such as fate and transport and hydrodynamic models. EPA believes that many 

models developed for general purposes might have potential use for understanding beach 

processes. However, at this time, no specific examples of easy-to-implement deterministic 

models exist (unlike with predictive statistical models). In contrast to the statistical models 

described earlier, deterministic models typically require specialized knowledge and expertise for 

successful implementation. It would likely be challenging for local beach managers to set up, 

calibrate, and run certain types of deterministic models with sufficient reliability and validity to 

protect public health. 

In the future, beach managers and modeling practitioners might want to further develop 

deterministic modeling tools to support beach monitoring and notification programs. Blending 

the performance of multiple types of models, a process known as stacking models, can help to 

account for complex variations in aquatic systems and improve accurate and timely predictions 

of WQS exceedances. A complex pattern of WQS exceedances was resolved by combining 

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hydrodynamic and statistical modeling at a popular beach in Florida (Zhu 2009). In the Great 

Lakes, water current, wind, and water level outputs of deterministic models are generated and 

can be used as independent variables in statistical models for predicting water quality at beaches, 

as well as for other purposes (NOAA 2012; Schwab and Bedford 1994). EPA’s FRAMES model 

combines the functions of multiple process models to estimate water quality. For information on 

FRAMES visit http://www.epa.gov/extrmurl/research/3mra.html. 

4.6.5 Determining Exceedances Using Predictive Models

Predictive models use past water quality data and current observed hydro-meteorological data as 

a basis for estimating water quality at a given time, as described in section 4.5. Models need a 

data set of observations that can vary in length, and ongoing calibration with periodic water 

quality determinations that can vary in frequency, to maintain a model’s calibration. Beach or 

program managers should assess their predictive models by correlating estimates of water quality 

with analytical results, the percentages of both Type I (false positive) and Type II (false 

negative) errors, or other methods that characterize water quality (e.g., Francy 2009, Gonzalez et 

al. 2012). 

The water quality estimates should be compared with beach notification thresholds. Beach or 

program managers can use beach notification thresholds that provide an adequate basis for public 

health protection. As stated in section 5.3, actions imposed based on the output of a predictive 

model can be lifted when the model is run again and new estimates indicate water quality 

conditions have improved to within acceptable parameters or, alternatively, when the results of a 

water quality sample show that FIB densities once again meet the applicable standard. 

Future directions that EPA considers likely for predictive tools for beach notification include 

forecasting beach water quality conditions a day or more into the future. Researchers are also 

attempting to develop models that would apply to more than one beach or to a region of 

shoreline. 

4.7 The 2012 RWQC Provide Context for Beach Monitoring Programs

This section summarizes relevant elements of the 2012 RWQC (section 4.7.1) and describes key 

considerations for beach monitoring programs (section 4.7.2). Section 4.7.3 discusses a new 

performance criterion—Adoption of New or Revised WQS and Identification and Use of a Beach 

Notification Threshold, Performance Criterion 10. 

4.7.1 2012 Recreational Water Quality Criteria 

On November 26, 2012, EPA released its revised RWQC. It is beyond the scope of this document 

to discuss the details of the RWQC. The criteria and associated information are available at 

http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/index.cfm. 

The 2012 RWQC, if adopted as recommended into state or tribal WQS, would be the applicable 

WQS in CWA programs, including issuing NPDES permits, assessing waters to determine 

whether they are attaining WQS, developing TMDLs, and conducting beach monitoring and 

notification programs funded under CWA section 406. However, the water quality distribution 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

on which a state’s or tribe’s WQS is based could also be the basis for selecting a beach 

notification threshold value to trigger beach notification actions (i.e., advisories and closures). 

EPA recommends that WQS based on the 2012 RWQC include the following values: 

• Magnitude. Magnitude is the numeric expression of the maximum amount of the

pollutant that might be present in a water body that supports the designated use.

• Duration. Duration is the period of time over which the magnitude is calculated.

• Frequency. Frequency of excursion7 describes the maximum number of times the

pollutant might be present above the magnitude over the specified time period (duration).

Criteria in a WQS should consist of a combination of magnitude, duration, and frequency of 

exceedance to protect the designated use (in this case, primary contact recreation).

As summarized below and described in greater detail in the 2012 RWQC document (USEPA 

2012b), EPA determined that the primary contact recreation designated use would be protected if 

the state or tribe adopted one of the sets of criteria values (table 4-4), consisting of a GM and an 

STV, into its WQS and EPA approved it. Note that EPA’s criteria recommendations are for a 

GM and an STV (rather than just a GM or just an STV) because, used together, they indicate 

whether the water quality is protective of the designated use of primary contact recreation. Using 

the GM alone would not protect for spikes in water quality because the GM alone is not sensitive 

to them.

The 2012 RWQC provide both GM values and STVs as upper-bound values (table 4-4). EPA 

recommends that the criteria magnitude be expressed as a GM value and an STV. These values 

correspond to the 50th and the 90th percentiles, respectively, of the same water quality 

distribution, and thus they are associated with the same level of public health protection.

Table 4-4. Recommended 2012 RWQC

Criteria elements

Estimated illness rate (NEEAR GI): 

36 NGI per 1,000 recreators

Estimated illness rate (NEEAR GI): 

32 NGI per 1,000 recreators

Magnitude Magnitude

Indicator GM

(CFU/100 mL)*

STV

(CFU/100 mL)*

GM

(CFU/100 mL)*

STV

(CFU/100 mL)*

Enterococci – marine 

and fresh water 35 130 OR 30 110

OR

E. coli – fresh water 126 410 100 320

Duration: The water body GM and STV should be evaluated over a 30-day interval. Frequency: The selected GM 

magnitude should not be exceeded in any 30-day interval, nor should there be greater than a 10 percent excursion 

frequency of the selected STV magnitude in the same 30-day interval.

*EPA recommends using EPA Method 1600 (USEPA 2009a) to measure culturable enterococci, or another equivalent method that

measures culturable enterococci, and using EPA Method 1603 (USEPA 2009b) to measure culturable E. coli, or any other 

equivalent method that measures culturable E. coli.

7 The frequency of excursion describes how often water quality sample values may surpass the combined magnitude 

and duration components before an exceedance of the WQS occurs and the water body is considered impaired.

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4.7.1.1 Geometric Mean

EPA is recommending that the GM of a water body be calculated in the same way as 

recommended in the 1986 criteria by taking the log10 of sample values, averaging those values, 

and then raising 10 to the power of that average.

4.7.1.2 Statistical Threshold Value

The STV is derived in a similar manner to the 1986 criteria SSM, by estimating the percentile of 

the expected water quality distribution around the GM criteria value. EPA recommends an STV 

that approximates the 90th percentile of the water quality distribution; it is intended to be a value 

that should not be exceeded by more than 10 percent of the samples measured over a 30-day 

period used to calculate the GM. EPA selected the estimated 90th percentile as the STV. The 90th

percentile accounts for the expected variability in water quality measurements, while limiting the 

number of excursions above the STV. It encourages additional monitoring because using the 90th

percentile reduces the number of samples that could exceed the criteria value (i.e., STV) within 

the 30-day duration period. This approach also encourages monitoring because it allows no 

excursion of the STV unless at least 10 samples are taken over the 30 days during which the 

magnitude component of the criteria is calculated.

In a departure from the 1986 criteria, EPA no longer recommends the concept of multiple use 

intensity values of the SSM. EPA’s 2012 RWQC include both the GM and STV, used together to 

adequately protect the designated use of primary contact recreation. Therefore, EPA 

recommends that states and tribes adopt both the GM and STV into their WQS. 

4.7.2 Threshold Values for Beach Notification Actions

4.7.2.1 Selection of Beach Notification Thresholds for States and Tribes Receiving Grants 

under CWA Section 406

The BEACH Act requires that states and tribes receiving grants under the act notify the public 

of any exceedance of or likelihood of exceedance of applicable WQS. When FIB levels at a 

beach exceed the applicable threshold, the responsible state or tribal agency issues a beach 

notification. Agencies generally issue beach advisories but, in some cases, might issue a beach 

closure notice. The purpose of these public notices is to inform the public of the potential risks 

associated with primary contact recreation in waters that exceed or are likely to exceed the 

applicable WQS. 

States and tribes must identify a beach notification threshold. This threshold does not need to be 

adopted into a state’s or tribe’s WQS. In the 2012 RWQC EPA suggests use of a specific value, 

the Beach Action Value (BAV), which is the 75th percentile value of the water quality 

distributions for the CWA section 304(a) recommended criteria (i.e., the 75th percentile values 

for 32 NGI per 1,000 recreators or 36 NGI per 1,000 recreators for one of the two indicatormethod combinations (enterococci or E. coli by culture) or qPCR (on a site-specific basis and 

with the appropriate analyses (see section 4.4.2.3)) as the threshold value for determining 

July 31, 2014 73 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

whether to take a beach notification action.8 EPA selected the 75th percentile value because it

corresponds to the percentile of the SSM values many states currently use as beach notification 

thresholds. 

In state and tribal programs funded by EPA grants under CWA section 406, it is critical that the 

selected beach notification threshold be based on the same water quality distribution as the 

state’s or tribe’s WQS. Any single sample above the threshold value would trigger a beach 

notification until collection of another sample below that value. EPA suggests a BAV at the 75th

percentile level in order to trigger an advisory at a lower FIB density than the STV. Because this 

BAV is a more conservative point on the same water quality distribution, states and tribes using 

this value will satisfy the statutory requirement for a notification action on an exceedance or 

likely exceedance of the WQS. 

EPA expects that states and tribes receiving beach grants under CWA section 406 will select as 

their beach notification threshold the BAV based on the 75th percentile value that corresponds to 

the indicator and illness rate in their adopted their WQS. (See table 4-5). However, they do have 

the option to submit a written justification to use a different value. The alternative value should 

be selected from the same statistical distribution as the illness rate and corresponding values 

adopted into state WQS, and the justification should explain why this value is preferable to the 

EPA-preferred 75th percentile value. This is discussed further in section 4.7.3. 

Table 4-5. Beach Action Values (BAVs)

Indicator

Estimated Illness Rate 

(NGI): 36 per 1,000 

primary contact 

recreators

Estimated Illness Rate 

(NGI): 32 per 1,000 

primary contact 

recreators

BAV (Units per 100 mL) BAV (Units per 100 mL)

Enterococci – culturable (fresh and marine)a 70 cfu OR 60 cfu

E. coli – culturable (fresh)b 235 cfu 190 cfu

Enterococcus spp.—qPCR (fresh and marine)c 1,000 cce 640 cfu

a Enterococci measured using EPA Method 1600 (USEPA 2009a), or another equivalent method that measures culturable 

enterococci.

b E. coli measured using EPA Method 1603 (USEPA 2009b), or any other equivalent method that measures culturable E. coli. c EPA Enterococcus spp. Method 1611 for qPCR (USEPA 2012a).

Before selecting any new beach notification threshold, states and tribes will continue to make 

notification decisions using the existing beach notification thresholds. In most states the existing 

beach notification values are SSM values from EPA’s 1986 RWQC document. These SSM 

values corresponded to the 75th percentile values of the 1986 RWQC statistical distribution.

8 All BEACH Act states and tribes that have not revised their WQS as directed in CWA section 303(i)(1)(A) were 

required by section 303(i)(1)(A) to have WQS as protective of human health as EPA’s 1986 bacteria criteria. 

Because EPA’s 1986 bacteria criteria recommendations were for the same fecal indicator bacteria in the 2012 

RWQC (enterococci and E. coli), the BAV in the 2012 RWQC have the requisite relationship with the applicable 

WQS in states that have not yet revised their WQS under CWA section 303(i)(1)(B).

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4.7.2.2 Alternative Beach Notification Thresholds

For beach programs not funded by EPA grants under CWA section 406(b), there are additional 

alternatives for states and tribes to consider. As with the BEACH Act states, neither use of the 

BAV nor any of the alternatives requires adoption into a state or tribal WQS. 

States and tribes that do not receive funding under CWA section 406 could choose to use any 

exceedance of the applicable STV as a threshold for notification for the purposes of their beach 

notification program, even without adopting it as a “do not exceed value” into their WQS. 

Alternatively, states and tribes that do not receive funding under CWA section 406 could choose 

to continue to use their current beach notification value; however, EPA encourages these states 

and tribes to use the BAV based on the 75th percentile value from the water quality distribution 

of their WQS. 

4.7.2.3 Preemptive Advisories

A state or tribe might have in place a preemptive advisory that automatically takes effect when 

conditions in the advisory (e.g., amount of rainfall) are met. The advisory is developed based on 

an analysis of monitoring data that shows the conditions under which the applicable WQS will 

be exceeded or is likely to be exceeded. The preemptive advisory would take effect and would 

end based on those predetermined conditions. Such an advisory might need to be recalibrated if 

the state’s or tribe’s beach notification threshold changes. 

4.7.2.4 Exceedances for EPA Enterococcus qPCR Methods

The 2012 RWQC document provides information on a qPCR Enterococcus spp. method (EPA 

Enterococcus spp. qPCR Method 1611; USEPA 2012a), discussed in section 4.4.2.2. EPA 

supports state use of qPCR methods for beach notification decisions in lieu of culture methods 

because it presents an opportunity to improve public health protection by enabling beach 

managers to take more timely notification actions at recreational beaches.

Because of EPA’s limited experience with qPCR performance across a broad range of 

environmental conditions, EPA encourages a site-specific analysis of the method’s performance 

before using the method in a beach notification program or adopting WQS based on the method. 

Section 4.4.2.3 describes a process for assessing the feasibility of using qPCR on a site-specific 

basis, including confirming that inhibition does not affect the method’s ability to accurately 

characterize water quality.

For states considering using qPCR Method 1611 or 1609, the 2012 RWQC provides the 

following GM, STV, and BAV values (table 4-6) for both the 36/1,000 and 32/1,000 primary 

contact recreators’ illness rates. Consistent with section 4.7.2.1, states and tribes using qPCR 

may also select a beach notification threshold that is other than the 75th percentile value, with 

appropriate justification.

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

Table 4-6. Values for qPCR

Element

36 NGI per 1,000 primary contact 

recreators

OR

32 NGI per 1,000 primary contact 

recreators

GM

(CCE per

100 mL)

STV

(CCE per

100 mL)

BAV

(CCE per

100 mL)

GM

(CCE per

100 mL)

STV

(CCE per

100 mL)

BAV

(CCE per

100 mL)

qPCR (sitespecific)* 470 2,000 1,000 300 1,280 640

*EPA Enterococcus spp. Method 1611 for qPCR (USEPA 2012a).

4.7.3 Implementation Requirements for Adopting the 2012 RWQC into State and

Tribal WQS and Identifying and Using a Beach Notification Threshold 

(Performance Criterion 10)

EPA is adding a new performance criterion, Adoption of New or Revised WQS and Identification 

and Use of a Beach Notification Threshold, Performance Criterion 10. The purpose of the 

criterion is to ensure that BEACH Act states and tribes adopt new or revised WQS as directed in 

CWA section 303(i)(1)(B); that is, within three years after EPA issues new or revised RWQC. 

The performance criterion also requires selection and use of an appropriate beach notification 

threshold. The specifics of performance criterion 10 will change from year to year. 

4.7.3.1 FY 2014 Overview 

The prerequisite for receiving an FY 2014 BEACH Act grant is to agree to a grant condition 

requiring the development of two schedules. BEACH Act states and tribes must include in the 

grant workplan for their FY 2014 grants a commitment to develop these schedules within 60 

days of grant award:

• Adopt new or revised WQS by FY 2016.

• Select and use an appropriate beach notification threshold by FY 2016.

Additionally, states and tribes must commit to begin following the schedules by the end of the 

grant year. If a state or tribe believes that it will be unable to develop either or both schedules 

within the allotted time frame, the state or tribe may request from the regional grant project 

officer an extension of up to 30 days for submitting the schedule(s). 

The schedules should contain milestones consistent with any relevant aspect of state or tribal law 

or custom that could affect the time frame for adopting new or revised WQS and identifying and 

using an appropriate beach notification threshold. Milestones might include, for example, 

drafting regulations, interagency coordination, public outreach and public comment periods, and 

legislative review. Where different state or tribal agencies must collaborate in order to develop 

and implement the two schedules, milestones might include creating and convening an 

interagency workgroup.

4.7.3.2 FY 2014: Adopting New or Revised Water Quality Standards

The new or revised WQS anticipated by the schedule must have RWQC expressed as a 

magnitude, duration, and frequency for the indicator, and an illness rate consistent with the CWA 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

section 304(a) recommendations in the 2012 RWQC or alternative criteria that are scientifically 

defensible and protective of the primary contact recreation use. 

In 2004, EPA promulgated WQS for 21 states. Since then, only six of those states have revised 

their WQS. The other states continue to use the WQS in the federal promulgation to make beach 

notification decisions. One purpose of this schedule is to ensure that such states update their 

underlying state regulations. 

All BEACH Act states and tribes must develop this schedule except those that have received an 

affirmative statement from EPA waiving the requirement. States and tribes that have RWQC that 

are consistent with EPA’s CWA section 304(a) 2012 RWQC recommendations may be eligible 

for such a waiver. EPA will expect the schedule to address specifically those elements that are 

not consistent with the 2012 RWQC. 

4.7.3.3 FY 2014: Identifying and Using a Beach Notification Threshold

The second schedule is for the state or tribe to identify and use an appropriate beach notification 

threshold. The state or tribe must commit to identify the indicator, illness rate, and value the state 

or tribe will use as its beach threshold at the completion of the second schedule. EPA expects 

that states and tribes will use BAVs as their notification thresholds (i.e., the 75th percentile value 

of the water quality illness rate from their new or revised WQS). States and tribes that want to 

use an alternative threshold must submit a written justification to EPA based in science, local 

water quality data, or monitoring experience. 

The 2012 RWQC explicitly did not recommend adoption of a beach threshold as part of the 

CWA section 304(a) recommendations for state and tribal WQS. However, some states and 

tribes may be required under state or tribal law to use only the values in their WQS as their beach 

notification threshold, and those WQS might not include an appropriate not-to-exceed threshold. 

In those situations, the state or tribe would need to change any legal requirement that precludes 

the state or tribe from using a value consistent with the requirements of this document. 

States and tribes must continue to use their existing beach notification thresholds based on the 

currently applicable WQS, e.g., SSM, until the state or tribe adopts new or revised WQS. When 

the state or tribe adopts new or revised WQS, it must have a beach notification threshold that can 

be used. 

4.7.3.4 FY 2015 and Beyond

Grant workplans for FY 2015 and beyond must include a commitment to continue to implement 

the schedules for adopting the WQS and identifying and using a beach notification threshold 

until the state or tribe has met all the milestones in both schedules. The workplans must also 

identify the indicator, illness rate, and value the state or tribe will use as its beach notification 

threshold and commit to making beach notification decisions as described. 

4.7.4 Use of RWQC in Identifying CWA Section 303(d) Impaired Waters

States that have EPA-approved WQS consistent with EPA’s 2012 RWQC recommendations 

must use the GM and STV (with corresponding duration and frequency) when identifying CWA 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 4 

section 303(d) impaired waters. EPA expects that beach water quality monitoring data from the 

beach program, and any other ambient monitoring, would be evaluated as part of a state’s or 

tribe’s data set to calculate the GM and STV for attainment purposes.

States also have the option to consider use of beach notification actions (advisories and closures 

in a recreational season) when determining whether the waters demonstrate nonattainment of 

their primary recreation use. In general, EPA recommends that states and tribes consider 

information about beach notification actions as a supplement to the GM and STV calculations. 

4.8 Delegation of Monitoring Responsibilities (Performance 

Criterion 5)

If a state delegates monitoring responsibilities to local governments, performance criterion 5 

requires the state grant recipient to describe the process by which the state may delegate these 

responsibilities to local governments and document any specific delegated responsibilities. States 

must notify EPA annually if there are any changes in delegated responsibilities.

4.9 Chapter 4 References

AOAC International. 1995. Official Methods of Analysis of AOAC International. 16th ed. Ed. 

P.A. Cunniff. AOAC International, Arlington, VA. 

APHA (American Public Health Association). 1998. Standard Methods for the Examination of 

Water and Wastewater. 20th ed. American Public Health Association, Washington, DC. 

ASTM (American Society for Testing and Materials International). 2000. Annual Book of ASTM 

Standards, vols. 11.01 and 11.02. American Society for Testing and Materials 

International, West Conshohocken, PA. 

Boehm, A.B. 2007. Enterococci concentrations in diverse coastal environments exhibit extreme 

variability. Environmental Science and Technology 41(24): 8227–8232. 

Boehm, A.B., S.B. Grant, J.H. Kim, S.L. Mowbray, C.D. McGee, C.D. Clark, D.M. Foley, and 

D.E. Wellman. 2002. Decadal and shorter period variability and surf zone water quality at 

Huntington Beach, California. Environmental Science and Technology 36(18): 3885–

3892.

Boehm, A.B., R.L. Whitman, M.B. Nevers, D. Hou, and S.B. Weisberg. 2007. Nowcasting 

recreational water quality. In Statistical Framework for Recreational Water Quality 

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exposure to urban runoff contaminated marine water. Water Research 46(7): 2176–86.

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bacteria levels. Water, Air, & Soil Pollution 223(8): 4841–4851. 

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Ohio Water Science Center. Presented at the National Beach Conference, October 11–13, 

2006, Niagara Falls, NY. Accessed March 2009. http://www.tetratechffx.com/beach_conf06/pdf/sessionVI/francy.pdf. 

———. 2009. Use of predictive models and rapid methods to nowcast bacteria levels at coastal 

beaches. Aquatic Ecosystem Health and Management 12(2): 177–182. 

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biological contaminants at beaches: A feasibility and case study. Environmental Science 

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Gonzalez, R.A., K.E. Conn, J.R. Crosswell, and R.T. Noble. 2012. Application of empirical 

predictive modeling using conventional and alternative fecal indicator bacteria in eastern 

North Carolina waters. Water Research 46(2012): 5871–5882. 

Griffith, J.F., K.C. Schiff, S.B. Weisberg, C.D. McGee, and C. Clifton. 2007. Efficacy of Shallow 

Water Sampling to Determine Exposure of Surfers to Indicator Bacteria at Marine 

Beaches. Southern California Coastal Water Research Project, Costa Mesa, CA.

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water quality monitoring: Lessons from a California demonstration project. Marine 

Technology Society Journal 45(2): 65–73. 

Haughland, R.A., S.C. Siefring, L.J. Wymer, K.P. Brenner, and A. P. Dufour. 2005. Comparison 

of Enterococcus measurements in freshwater at two recreational beaches by quantitative 

polymerase chain reaction and membrane filter culture analysis. Water Research

39(2005): 559–568. 

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Haugland, R.A., S. Siefring, J. Lavender, and M. Varma. 2012. Influences of sample interference 

and interference controls on quantification of enterococci fecal indicator bacteria in 

surface water by the qPCR method. Water Research 46(18): 5989–6001. 

IITF (Indiana Interagency Task Force). 1999. Standard Operating Procedure for Recreational 

Water Collection and Analysis of E. coli in Streams, Rivers, Lakes and Wastewater. 

Indiana Interagency Task Force on E. coli, LaPorte County Health Department, LaPorte, 

IN.

Leecaster, M.K., and S.B. Weisberg. 2001. Effect of sampling frequency on shoreline 

microbiology assessments. Marine Pollution Bulletin 42(11): 1150–1154. 

Le Fevre, N.M., and G.D. Lewis. 2003. The role of resuspension in enterococci distribution in 

water at an urban beach. Water Science and Technology 47(3): 205–210. 

Nevers, M.B., and R.L. Whitman. 2005. Nowcast modeling of Escherichia coli concentrations at 

multiple urban beaches of southern Lake Michigan. Water Research 39(20): 5250–5260. 

NOAA (National Oceanic and Atmospheric Administration). 2012. Great Lakes Coastal 

Forecasting System. National Oceanic and Atmospheric Administration, Great Lakes 

Environmental Research Laboratory, Ann Arbor, MI. Accessed June 2012. 

http://www.glerl.noaa.gov/res/glcfs. 

Noble, R.T., I.M. Lee, and K.C. Schiff. 2003. Inactivation of Indicator Bacteria from Various 

Sources of Fecal Contamination in Seawater and Freshwater. Southern California 

Coastal Water Research Project. 2001-02 Biennial Report, pp. 164–163. 

Noble, R.T, A.D. Blackwood, J.F. Griffith, C.D. McGee, and S.B. Weisberg. 2010. Comparison 

of rapid quantitative PCR-based and conventional culture-based methods for enumeration 

of Enterococcus spp. and Escherichia coli in recreational waters. Applied and 

Environmental Microbiology 76(22): 7437–7443. 

Office of the Federal Register. 2003. Guidelines Establishing Test Procedures for the Analysis of 

Pollutants; Analytical Methods for Biological Pollutants in Ambient Water; Final Rule. 

Office of the Federal Register, National Archives and Records Administration, 

Washington, DC. Fed. Regist., Jul. 21, 2003, 68: 43272-43283. 

Olyphant, G.A., and R.L. Whitman. 2004. Elements of a predictive model for determining beach 

closures on a real time basis: The case of 63rd Street Beach Chicago. Environmental 

Monitoring and Assessment 98(1–3): 175–190. 

Schwab, D.J., and K.W. Bedford. 1994. The Great Lakes Forecasting System. In Coastal and 

Estuarine Studies: Coastal Ocean Prediction, ed. C.N.K. Mooers. American Geophysical 

Union, Washington, DC. 

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total DNA isolation from salmonid fishes. Journal of Fish Biology 40(6): 963–965.

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USEPA (U.S. Environmental Protection Agency). 1978. Microbiological Methods for 

Monitoring the Environment, Water and Wastes. EPA 600/8-78-017. U.S. Environmental 

Protection Agency, Washington, DC. 

———. 1999. Review of Potential Modeling Tools and Approaches to Support the BEACH 

Program. EPA-823-R-99-002. U.S. Environmental Protection Agency, Office of Science 

and Technology, Washington, DC.

———. 2005. The EMPACT Beaches Project: Results from a Study on Microbiological 

Monitoring in Recreational Waters. EPA 600/R-04/023. U.S. Environmental Protection 

Agency, Office of Research and Development, National Exposure Research Laboratory, 

Washington, DC. 

———. 2007. Report of the Experts’ Scientific Workshop on Critical Needs for the Development 

of New or Revised Recreational Water Quality Criteria. EPA-823-R-07-006. U.S. 

Environmental Protection Agency, Office of Water and Office of Research and 

Development, Washington, DC. 

———. 2009a. Method 1600: Enterococci in Water by Membrane Filtration Using MembraneEnterococcus Indoxyl- β-D-Glucoside Agar (mEI). EPA 821/R-09/016. 

U.S. Environmental Protection Agency, Office of Water, Washington, DC. 

———. 2009b. Method 1603: Escherichia coli (E. coli) in Water by Membrane Filtration Using 

Modified Membrane-Thermotolerant Escherichia coli Agar (Modified mTEC). EPA 821-

R-09-007. U.S. Environmental Protection Agency, Office of Water, Washington, DC. 

———. 2009c. Office of Water Quality Management Plan, revision 3. EPA-821-R-09-001. 

U.S. Environmental Protection Agency, Office of Water, Washington, DC. 

———. 2010a. Predictive Modeling at Beaches. Vol. 2, Predictive Tools for Beach Notification.

EPA-600-R-10-176. U.S. Environmental Protection Agency, National Exposure Research 

Laboratory, Athens, GA. 

———. 2010b. Predictive Tools for Beach Notification. Vol. 1, Review and Technical Protocol. 

EPA-823-R-10-003. U.S. Environmental Protection Agency, Office of Water, 

Washington, DC. 

———. 2010c. Sampling and Consideration of Variability (Temporal and Spatial) for 

Monitoring of Recreational Waters. EPA-823-R-10-005. U.S. Environmental Protection 

Agency, Office of Water, Washington, DC. 

———. 2012a. Method 1611: Enterococci in Water by TaqMan® Quantitative Polymerase 

Chain Reaction (qPCR) Assay. EPA-821-R-12-008. U.S. Environmental Protection 

Agency, Office of Water, Washington, DC. 

———. 2012b. Recreational Water Quality Criteria. EPA 820-F-12-058. U.S. Environmental 

Protection Agency, Office of Water, Washington, DC. 

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———. 2013a. Acceptability of the EPA qPCR Test at Your Beach. EPA 820-R-13-012. 

U.S. Environmental Protection Agency, Office of Water, Washington, DC. 

———. 2013b. Method 1609: Enterococci in Water by TaqMan® Quantitative Polymerase 

Chain Reaction (qPCR) with Internal Amplification Control (IAC) Assay. EPA-820-R13-005. U.S. Environmental Protection Agency, Washington, DC. 

———. In press-a. Alternative Health Relationships Technical Support Materials. U.S. 

Environmental Protection Agency, Office of Water, Washington, DC. 

———. In press-b. Site-Specific Alternative Criteria Technical Support Materials for Alternative 

Fecal Sources. U.S. Environmental Protection Agency, Office of Water, Washington, 

DC.

———. In press-c. Site-Specific Alternative Criteria Technical Support Materials for Alternative 

Indicators and Methods. U.S. Environmental Protection Agency, Office of Water, 

Washington, DC. 

Wade, T.J, R.L. Calderon, K.P. Brenner, E. Sams, M. Beach, R. Haugland, L. Wymer, and A.P. 

Dufour. 2008. High sensitivity of children to swimming-associated gastrointestinal 

illness: Results using a rapid assay of recreational water quality. Epidemiology 19(3): 

375–383. 

Wade, T.J., E. Sams, K.P. Brenner, R. Haugland, E. Chern, M. Beach, L. Wymer, C.C. Rankin, 

D. Love, Q. Li, R. Noble, and A.P. Dufour. 2010. Rapidly measured indicators or 

recreational water quality and swimming-associated illness at marine beaches: A 

prospective cohort study. Environmental Health 9:66. 

Wymer, L.J. 2007. The EMPACT Beaches: A Case Study in Recreational Water Sampling. 

Chapter 7 in Statistical Framework for Recreational Water Quality Criteria and 

Monitoring, ed. L. Wymer, pp. 113–134. John Wiley and Sons, Ltd., UK. 

Zhu, X. 2009. Modeling Microbial Water Quality at a Non-Point Source Subtropical Beach. 

Master’s thesis, University of Miami, Coral Gables, FL. 

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Chapter 5: Public Notification and Risk Communication

This chapter describes the performance criteria and technical guidance related to public 

notification and risk communication. It includes information on developing and implementing a 

plan that describes measures to notify the public of an exceedance or likely exceedance of the 

applicable WQS and inform them of the potential risks associated with water contact activities in 

recreation waters that do not meet applicable WQS. Assessing the information needs of 

stakeholders, developing message content, and selecting communication methods are key 

elements of the plan. This chapter discusses a variety of communication options, such as beach 

signs, news releases, websites, and social networking. The chapter also covers BEACH Act 

requirements for notifying EPA and local agencies when WQS are exceeded and reporting 

notification activities.

To the extent possible, states and tribes should be moving toward same-day notification of 

exceedances and prompt reporting by using tools that provide rapid results (i.e., rapid analytical 

methods and predictive models) and tools that facilitate rapid communication of those results 

(e.g., electronic notification and real-time reporting).

This guidance reflects those goals in the addition of three new specific requirements under the 

performance criteria. These requirements apply to states and tribes that receive grants under 

CWA section 406 after this document becomes final: 

• Performance criterion 2, Tiered Monitoring Plan, now requires that states and tribes 

consider the potential use of predictive tools when developing a tiered monitoring plan. 

• Performance criterion 2, Tiered Monitoring Plan, now requires that states and tribes 

consider the appropriateness of qPCR methods when developing a tiered monitoring plan. 

• Performance criterion 4, Monitoring Report Submission, now requires that states and 

tribes make monitoring data available in a timely manner to the public on a website.

5.1 Performance Criteria

Performance criteria 6 through 9 describe the four requirements for a public notification and risk 

communication program: 

• Public Notification and Risk Communication Plan (performance criterion 6).

• Actions to Notify the Public (performance criterion 7).

• Notification Report Submission (performance criterion 8).

• Delegation of Notification Responsibilities (performance criterion 9).

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Key changes to chapter 5 from the 2002 guidance document

• More clearly ties notification to the tiered monitoring plan (section 5.2).

• Adds a specific requirement to identify measures to inform the public of the risks of

swimming in contaminated water (section 5.2).

• Adds information about risk communication objectives, notification content, and

notification methods (sections 5.2 and 5.4).

• Discusses new beach notification and communication tools, such as social media, email,

and text messages (section 5.4).

• Provides guidance on when to issue or remove a notification (section 5.3).

• Combines performance criteria 5 through 7 into performance criterion 6 to eliminate

duplication (section 5.2).

• Divides performance criterion 8 into two criteria—performance criteria 8 and 9—to

separate disparate activities (sections 5.5 and 5.6).

Table 5-1 provides details on the general and specific requirements of the performance criteria 

and cross-references them to the sections in this chapter where they are discussed. As explained 

in chapter 2, monitoring and notification programs funded with BEACH Act implementation 

grants must be consistent with the performance criteria. 

Table 5-1. Performance criteria details

Performance criteria Chapter 

General requirements Specific requirements section

Public Notification and Risk Communication 

Plan (Performance Criterion 6). States and tribes 

must develop public notification and risk 

communication plans. 

• Identify measures to notify EPA and local

governments (if applicable) when indicator bacteria

levels exceed a beach notification threshold.

• Identify measures to notify the public when a beach

notification threshold has been exceeded by posting a

sign or functional equivalent.

• Identify measures that inform the public of the

potential risks associated with water contact activities

in the coastal recreation waters that do not meet

applicable WQS.

• Provide for public review of the public notification and

risk communication plan.

5.2

Actions to Notify the Public (Performance 

Criterion 7). States and tribes must give notice to 

the public that the coastal recreation waters are not 

meeting or are not expected to meet applicable 

WQS or the beach notification threshold for 

pathogens and pathogen indicators.

• Promptly issue a public notification for exceedance of

the beach notification threshold when there is no

reason to doubt the accuracy of the sample.

• If there is a reason to doubt the accuracy of the first

sample, the state agency may resample before

issuing a notification.

5.4

Notification Report Submission (Performance 

Criterion 8). States and tribes must compile their 

notification actions in timely reports submitted to 

EPA. 

• States and tribes must report to EPA at least annually,

or at a frequency the EPA Administrator determines, on

the occurrence, nature, location, pollutants involved,

and extent of any exceedances of any WQS for

pathogens and pathogen indicators.

5.5

Delegation of Notification Responsibilities 

(Performance Criterion 9). States must describe 

any delegation of notification responsibilities that 

they have made, or intend to make, to local 

governments. 

• States must identify any local governments to which

they have delegated responsibility for implementing a

notification program and describe the process by

which the state may delegate such authority.

5.6

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 5

5.2 Public Notification and Risk Communication Plan (Performance 

Criterion 6)

Performance criterion 6 requires states and tribes to develop a public notification and risk 

communication plan. The plan must describe the state’s or tribe’s public notification efforts; 

identify measures used to inform the public of an exceedance or likely exceedance of the 

applicable WQS; and address a new requirement to identify measures to inform the public about 

the potential risks associated with water contact activities in coastal recreation waters that do not 

meet the applicable beach notification thresholds. Below are the key steps of creating a public 

notification and risk communication plan: 

• Creating a risk communications strategy.

• Assessing needs and establishing trust.

• Crafting beach notifications.

• Evaluating outcomes.

EPA recognizes that states and tribes usually have such plans in place. States and tribes should 

review and evaluate their plans periodically to keep them current with the information needs of 

the community, conditions associated with a contamination problem, and resources and 

personnel available to the responsible agency. Importantly, careful evaluation will help to 

determine to what extent the public notification and risk communication program is achieving its 

objectives and what components should be revised and improved. 

5.2.1 Creating a Risk Communication Strategy

5.2.1.1 Risk Communication Partners

Public notification and risk communication are primarily information-sharing processes among 

three key groups of people: 

• Stakeholders—the target audiences that receive and respond to beach advisory and

closing information. They include swimmers and other people (such as seashore vendors)

who might be affected by beach actions. Government agencies that have an interest in

beach actions or must be notified if a beach action is issued are included in this category.

State agencies should consider the stakeholders’ beliefs, attitudes, and backgrounds when

developing notification content and appropriate ways to distribute it. Stakeholders can

provide valuable feedback that helps the responsible agency achieve the greatest positive

impact in the community.

• Agency technical experts—the people responsible for beach monitoring and research

activities; setting policy and procedures in response to violations of WQS; and

generating, interpreting, and assessing water quality data. They provide the scientific

foundation for the notification and risk communication program.

• Risk communicators—the people responsible for designing and implementing the

notification and risk communication program. They typically rely on a two-way

communication process with the other partners to define program objectives, assess

information needs, and develop communication strategies.

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Those three groups should work toward the common objective of reducing the risk of disease to 

users of recreational waters.

5.2.1.2 Types of Public Notifications

When indicator bacteria levels at a beach exceed the beach notification threshold, the responsible 

agency issues an advisory or closure to inform the public of an exceedance or likely exceedance 

of the applicable WQS and the potential risks associated with swimming and other water contact 

activities.

• Beach advisories (or postings in California) are recommendations to avoid swimming at 

the beach, or beach area, because of an increased risk of contracting a water-related 

illness. The action does not, however, officially close a beach to the public. Types of 

advisories include: 

– Water quality exceedance advisories, which notify the public of an exceedance of 

applicable beach notification thresholds on the basis of water quality sampling or the 

likelihood of an exceedance on the basis of modeling. 

– Permanent advisories, which notify the public of a continuing potential human health 

risk associated with use of the water. These might be issued because of the presence 

of naturally occurring organisms or human influences that cause a continuous or 

reoccurring exceedance of a WQS. 

– Preemptive advisories, which notify the public of the likelihood of higher FIB levels 

at certain times. Preemptive advisories are typically based on having done sufficient 

monitoring in the past to support an assumption that water quality will exceed the 

beach notification threshold for a certain period of time after a defined event. An 

event might be significant rainfall that typically results in flushing bacteria from the 

land into the water, high-temperature conditions that stimulate bacterial productivity, 

or prevailing wind conditions that cause the transport of contaminated water from 

known polluted areas. 

• Beach closing typically means that the beach, or a beach area, is officially closed to the 

public. Whether to close a beach is a local decision; EPA does not set beach closure 

requirements or conditions. States and tribes have the flexibility to close the entire beach 

or just the recreational water adjacent to the beach. For some jurisdictions, closure is a 

recommendation; for others, it might be enforced. EPA recommends, however, that a 

closing be issued if a clear public health hazard, such as a sewage line break or other 

high-risk contamination source, is present. During such a closing, no one should be in the 

water. Lifeguards might not be present at the beach. The beach could be closed to the 

public temporarily or for an extended period. 

A public notification is also issued when a beach action is lifted or suspended. 

5.2.1.3 Risk Communication Objectives

A complete set of clear, concise, and measurable objectives helps to guide the development of a 

public notification program and serves as a set of measuring tools for program evaluation. In the 

case of beach closings, the objective is usually clear-cut—the public is prohibited from 

swimming because a public health hazard (such as a sewage line break or other high-risk 

July 31, 2014 86 
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 5

contamination source) or a safety issue (such as dangerous rip tides) is present. The closing 

message is usually presented in a commanding tone that leaves no doubt that the message should 

be followed. An advisory, on the other hand, sends a different message because it suggests that 

the beachgoer consider the information in determining whether to follow the recommendations.

Risk communicators typically take two basic approaches with advisories (USEPA 2011): 

• Informing the public of the potential risk of swimming in contaminated water so that 

people can make their own judgments and risk management decisions. Communication 

usually has a straightforward, matter-of-fact tone.

• Influencing the public by presenting a convincing argument why they should follow 

recommendations that safeguard their health. The message usually has a cajoling tone.

Selecting a communication approach depends on the beliefs and attitudes of the stakeholders. 

Beliefs and attitudes, in turn, are shaped by many factors, including the credibility, accessibility, 

and adequacy of the information sources. Lifestyle, perceptions, and the opinions of others also 

play roles in behavior choices. Gaining an understanding of the beliefs and attitudes of 

stakeholders is key when choosing a communication approach. 

To keep the program dynamic and relevant, periodically updating objectives is one of the most 

important ongoing tasks of the risk communication partnership. 

5.2.2 Addressing Needs and Establishing Trust

5.2.2.1 Assessing the Information Needs of Stakeholders

A majority of beach actions issued by states and tribes are beach advisories. Unlike official 

beach closings, cooperation is voluntary; people must make up their own minds about following 

advisories. 

At one extreme, some in the community will accept the advisory recommendations, no questions 

asked. Perhaps they deem the issuing agency trustworthy and committed to looking out for their 

welfare. Perhaps they experienced sickness after swimming in contaminated water and do not 

want to repeat the unpleasant episode. Whatever the motivation, these people need no further 

information to convince them to follow an advisory recommendation. 

At the other extreme, some will reject the advisory recommendations outright. They might think 

the issuing agency is untrustworthy or simply mistaken. They might believe they are immune to 

waterborne disease because they have never become sick from swimming. Perhaps they feel the 

benefits associated with their water recreation activities are worth the risk of getting sick. 

Whatever the reason, these people will likely never change their beach-going behavior because 

of an advisory notification.

Most stakeholders fall somewhere between those two extremes. They are open to the 

recommendations but need more background information or rationale to convince them to follow 

the recommendations. For that reason, it is important to study the target audiences and assess 

both their informational needs and the best methods for delivering information to them. Such 

assessments are critical for establishing trust.

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5.2.2.2 Establishing Trust

Usually risk communication messages are judged primarily on the basis of whether the source 

can be trusted, and only secondarily on the basis of the message itself (USEPA 2011). EPA 

developed the Seven Cardinal Rules of Risk Communication (USEPA 1988) to help risk 

communicators foster credibility and trust within a community: 

1. Accept and involve the public as a legitimate partner, identifying stakeholder groups 

and incorporating their concerns and perspectives in communication strategies. 

2. Plan carefully and evaluate communication efforts, establishing clear objectives and 

developing two-way communication.

3. Listen to the public’s concerns, making no assumptions about what people know, think, 

or want done about risks. 

4. Be honest, frank, and open, not minimizing or exaggerating the level of risk and 

discussing data uncertainties, strengths, and weaknesses.

5. Coordinate and collaborate with other credible sources, releasing information through 

other credible organizations as appropriate. 

6. Meet the needs of the media, being open and accessible to reporters. 

7. Speak and write simply and clearly, using nontechnical language. 

5.2.3 Crafting Beach Notifications

Performance criterion 1 in chapter 3 addresses the process for evaluating beaches and classifying

them into a tiered ranking system on the basis of potential risks to human health and beach 

usage. The tiered ranking system helps grantee agency administrators efficiently allocate 

monitoring and public notification resources among the beaches they manage.

This approach, however, does not absolve agencies from their mandated responsibility to 

communicate potential health risks in a timely manner at any beach that has exceeded or is likely 

to exceed a beach notification threshold. Therefore, at a minimum, states and tribes must post 

notification of an advisory or closure (signs or their functional equivalent). Beyond this 

minimum requirement, states and tribes may choose to direct additional resources to beach 

notifications. 

5.2.3.1 Developing Notification Content

The content of a beach advisory refers to the complete set of information in an advisory (USEPA 

1995). Most advisories include the following: 

• Core recommendations, which state the specific actions beachgoers should take to 

protect and preserve their health. 

• Supplemental information, which supports the core recommendations. Depending on the 

approach, the information can be designed to inform or influence stakeholders to follow 

the core recommendations.

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 5

The content of core recommendations is derived from the state, tribal, and EPA risk assessment and 

management processes in conjunction with the established policy and procedures of the responsible 

agency. A core recommendation should be simple, clear, and authoritative. For example:

• For beach closings:

– Beach Closed—No Swimming—No Wading. 

– Stay Out of the Water.

– Keep Out—Contaminated Water.

• For beach advisories: 

– Warning—Water Contact Might Cause Illness.

– Caution—Water Quality Advisory. 

– Water Quality Today Is Rated Poor. 

Supplemental information, on the other hand, is crafted considering several factors, including the 

objectives of the communication program, the informational needs of the stakeholders, the 

communication approach (informing or influencing), and the type and limitations of the 

dissemination method. Most supplemental information fits into one of four broad categories: 

• Information about the current action. 

– Location or beach length affected by the action.

– Reason for the beach action (e.g., high levels of fecal bacteria).

– Duration of the beach action (e.g., resampling and conditions to be met before the 

action is lifted).

– Cause or source of the contamination (e.g., untreated sewage, sewer line break, and 

high runoff). 

– Scales of risk (e.g., high, medium, and low). 

• Information about the monitoring program and action policies. 

– Water quality sampling (e.g., schedule, indicator bacteria, and pathogens). 

– Monitoring results that trigger an action (e.g., instantaneous criterion and rolling 

average criterion).

– Monitoring limitations (e.g., lag between sampling and lab results). 

– Water quality trends (e.g., past notification actions).

• Behavior modification and instructions. 

– List of unsafe activities (e.g., swimming and wading). 

– Potential consequences of swimming in contaminated water (e.g., gastritis and ear 

infection). 

– Reporting a beach-related illness (e.g., hotline). 

• Agency information. 

– Contact information. 

– Sources of additional information (e.g., website and other outreach efforts). 

– Agency follow-up to address the problem. 

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 5

5.2.3.2 Selecting Notification Methods

State beach program managers typically use a combination of notification methods to reach the 

diversity of stakeholders in the community and the nonresidents that might travel to the beach. 

Whatever methods are selected, they should be designed so that they complement and reinforce 

each other (USEPA 2011). For example, beach signs, which are necessarily limited in size and 

scope, should reference a website or source with more detailed information. 

The basic challenges for the risk communicator are to identify the various stakeholder groups 

and match them with effective notification methods given the constraints of agency resources. 

States and tribes might choose to direct additional resources to higher-priority beaches. For 

example, a state or tribe might determine that low-cost tools, such as news releases (discussed in 

section 5.4.2) and notices on a website (discussed in section 5.4.3.1) are appropriate for Tier 2 

and 3 beaches and that, in addition, social media tools (discussed in section 5.4.4.3) and 

electronic signs are appropriate for Tier 1 beaches.

Divergent groupings of stakeholders might be best reached through different methods of 

communication: 

• Older versus younger beachgoers. Younger people are more likely to use social media 

(e.g., Facebook and Twitter) than are older beachgoers, who typically prefer newspapers, 

radio, television, and other traditional media for their news. 

• Active versus inactive information seekers. Some people are more willing than others to 

actively seek out water quality information before deciding to go to the beach. 

• Tourists versus locals. Residents are more familiar with local information outlets, 

whereas nonresidents tend to rely on large-scale public media outlets such as state 

websites.

• Differing cultural backgrounds and practices. Often different cultures use completely 

different information outlets, a problem compounded if language barriers also exist. In 

this case, messages should be translated.

• People who receive information before visiting the beach versus people at the beach.

For some beachgoers, the only time to communicate information to them is while they 

are at the beach. They do not seek out information before their trip to the beach. 

Example of Notice in Spanish

Aviso! Corriente de agua/agua del drenaje de tormenta puede causar enfermedades. Evite 

contacto con agua de desague y con el area donde desemboca al oceano.

Division de Salud Ambiental del Condado de Orange. Para mas informacion llamar al 

714-667-3752.

English Translation

Warning! Runoff or storm drain water may cause illness. Avoid contact with ponded or flowing 

runoff and the area where runoff enters the ocean.

Orange County Environmental Health Division. For further information, call 714-667-3752. 

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5.2.4 Evaluating Public Notification and Risk Communication Plans

Evaluations of both new and established public notification and risk communication plans are 

useful to ensure that the plans continue to meet the needs of the public and the objectives of the 

state agency. A state or tribe should conduct periodic evaluations to document the short- or longterm results of its public notification and risk communication plan and to evaluate whether 

objectives were achieved. These evaluations determine whether the beach advisories and 

closings have been effective in communicating health risks to the public. 

States and tribes do not need to wait until the end of a beach season to evaluate plan 

implementation. Evaluation activities can include regular contacts with communication partners 

(media personnel, website owner, and stakeholders) to evaluate the timing and adequacy of 

advisory information. It can also be useful to interview stakeholders or focus groups or conduct 

mail and telephone surveys to assess how well the advisory information is reaching the target 

audience and how receptive they are to that information. A large sample size is often needed for 

the plan evaluators to measure statistically significant outcomes and effects in large regions 

(e.g., statewide).

Before developing a public notification and risk communication plan, or while evaluating or 

updating the plan, a state or tribe can mail surveys or conduct them over the telephone to obtain 

feedback from a subset of the target audience. The state or tribe can use the survey to determine 

the public’s knowledge about the following: 

• Human health risks of swimming in contaminated water.

• Specific advisory recommendations. 

• The advisory process. 

Questions to ask include: 

• Did people receive enough information to make an informed decision? 

• Were people protected from bacterial contamination? Did the public respond positively to 

the advisory and closing program? 

• Are signs, press releases, websites, and social media presenting appropriate and accurate 

information? 

• How many people pay attention to communication methods such as beach signs and 

physical barriers?

• How many people actually contact a telephone hotline, visit a website, sign up on 

Facebook or Twitter, or choose to receive text messages to obtain water quality 

information for a beach? 

A state can design a survey to assess the following:

• The public’s reaction to advisories and closings. 

• The public’s willingness to adhere to advisory and closing recommendations. 

• The public’s suggestions for better communication methods. 

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5.2.5 When to Notify EPA and Local Governments

As part of performance criterion 6, states and tribes must develop public notification and risk 

communication plans that identify measures to notify EPA and local agencies with jurisdiction 

over the land adjoining the beach of water quality exceedances. The annual reporting under 

performance criterion 8 satisfies this requirement to notify EPA. States must notify local 

agencies whenever they issue a notification action. 

5.3 When to Issue and Remove a Notification

A public notification and risk communication plan should establish clear policies and procedures 

for each type of notification the responsible agency uses. As general guidance, EPA recommends 

that as soon as the lab analyzes and reviews sampling data, the lab should report them to the 

beach or program manager. In addition to how and when to issue a beach advisory or closing, the 

plan should include the conditions that must be met to lift the advisory or closing. It should cover 

all the methods the state or tribe might use to issue an advisory, including sampling results, 

preemptive advisories, and predictive tools. 

5.3.1 When to Issue a Notification

As soon as the data reviews and data quality assessment are completed, based on sampling, 

modeling, or preemptive advisories, concentrations for the specified bacterial indicators should 

be reported to the beach manager. If a sample indicates that there is an exceedance or a likely 

exceedance of a WQS or other notification threshold value, the state or tribe must immediately 

issue a public notification according to the policy and procedures established in the public 

notification and risk communication plan unless there is a reason to doubt the accuracy of the 

first sample. If there is doubt (based on predefined QA measures), the responsible agency should 

resample. 

If the decision is to resample, the resampling should be done in accordance with the discussion in 

section 4.3.2.3. If the decision is to notify the public, EPA recommends the following actions: 

• Prompt notification of the owner, manager, or operator and/or the lifeguards. When 

sample results indicate an exceedance of a beach notification threshold, the appropriate 

agency must promptly notify the beach manager/operator and appropriate staff members 

(e.g., lifeguards). This approach ensures that the responsible authorities know that action 

should be taken to ensure the safety of the beach employees. 

• Prompt public notification. The appropriate agency must promptly notify the public of 

an exceedance of a beach notification threshold—by either a sign or functional equivalent 

(see section 5.4). Notification typically should occur at the point of beach access. States 

and tribes must promptly issue a notification when there is an exceedance of a beach 

notification threshold based on modeling results or a preemptive threshold. 

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5.3.2 When to Remove a Notification

EPA recommends that states and tribes follow these procedures at all beaches before lifting an 

advisory or closing: 

• For advisories based on sampling results, sample and compare the bacterial 

concentrations with the applicable WQS or other applicable thresholds to determine 

whether the levels no longer exceed the threshold. 

• In the case of a preemptive advisory, remove an advisory or reopen a beach after the 

number of hours or days identified in the advisory has elapsed after the event or 

condition. A state or tribe could also sample before lifting a preemptive advisory. Best 

professional judgment could also be used to supplement the decision to reopen a beach. A 

state or tribe should develop protocols for preemptive advisories. 

• Beach advisories imposed on the basis of a predictive model could be lifted when an 

additional model run estimates that water quality conditions have improved to within 

acceptable parameters or, alternatively, when the results of a water quality sample show 

that indicator densities once again meet the applicable threshold. 

5.4 Actions to Notify the Public (Performance Criterion 7)

Programs funded with BEACH Act grants must notify the public (i.e., post signs or use 

functionally equivalent communication measures) of an exceedance of a beach notification 

threshold. Functionally equivalent communication measures are those that effectively 

communicate to the target audience the potential health risk in a manner at least as timely as 

posting signs at the beach. 

A functionally equivalent measure at the point of access could be a visual notice such as a flag at 

a beach or personal interaction with beach or park personnel. Other functionally equivalent 

measures not provided at the point of access include mass media (newspapers, television, and 

radio), websites, telephone hotlines, and Internet tools. 

Historically, traditional forms of mass media such as newspapers, television, and radio were 

commonly used to communicate notification information to stakeholders. Although such 

traditional forms of mass media remain important information sources for many segments of the 

community, the development of the Internet and electronic media has eroded their importance to 

other segments. Consequently, risk communicators should identify the various stakeholder 

groups and then match the notification methods to the way each group gets its news. 

A beach or program manager should consider the type of beach and its tier when selecting the 

appropriate notification measures. The measures chosen should be consistent with the risk and 

use of the beach, as described in chapter 3. 

5.4.1 Beach Signs

Beach signs are the most direct way to communicate a notification action to people at the beach. 

The signs should be where people are most likely to see and read them; beach entrances, access 

points, and lifeguard stations are common choices. It is important that the core message content 

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(see section 5.2.3.1) is large enough to be read from a distance, and the sign itself should have 

design qualities that attract the eye. Electronic signs can also be used, as they are in Huntington 

Beach, California, and other places. 

Emphasize and enhance core content by using the following: 

• Capital letters, boldface fonts, and exclamation points. 

• Vivid colors for the text or background; red, orange, and yellow 

are the most common. 

• Images or icons, such as a stop sign or the universal “no” symbol 

(figure 5-1).

• Eye-catching sign shape.

• Attention-grabbing graphics. 

Figure 5-1. The 

universal symbol for 

“No.”

Because signs have limited space, any supplemental content should be brief and to the point. 

(See the New York City Department of Health and Mental Hygiene case study in the text box 

below.) EPA recommends that signs include a reference to where further information can be 

obtained. 

In addition to posted beach signs, notification information can often be displayed at other 

locations at the beach, such as parking lots, bathhouses, and lifeguard stands. Permanent posters 

in those locations that provide more in-depth information about the beach program, water quality 

monitoring, and other issues can also be developed. 

The Centers for Disease Control and Prevention’s Healthy Swimming and Recreational Water 

website contains excellent health promotion materials such as brochures, fact sheets, and graphic 

(funny and eye-catching) posters about healthy swimming behaviors. The website is at 

http://www.cdc.gov/healthywater/swimming/resources/index.html. 

Tips to Improve the Effectiveness of Signs

• Use a standard format for notification signage throughout the state so it is familiar and 

easily recognizable to beachgoers.

• Change signage promptly when bacteria levels change.

• Provide signage in other languages if non-English-speaking people use the beach.

• Use a scale to communicate the severity of the risk. For example, a green, yellow, and red 

scale is often used to indicate low, medium, and high levels of bacteria.

• Make the sign as sturdy and vandal-proof as possible.

• Avoid small print and technical jargon.

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New York City Department of Health and Mental Hygiene New Texting Program

In 2013 the New York City Department of Health and Mental Hygiene (DOHMH) conducted focus 

groups and intercept surveys of beach patrons in an effort to improve risk communication to the 

public when beach water quality exceeds acceptable standards. In response to public input on 

several beach signs, DOHMH developed new public notification signs for its beach water quality 

warnings. These signs communicate the core recommendations clearly and directly and provide 

supplemental information on the basis for the advisory or closure.

July 31, 2014 95 

DOHMH also developed a free texting service for the 2014 beach season so you can “Know 

Before You Go” if your beach is open, under advisory, or closed. Beachgoers can enroll by 

texting the word “beach” to 877-877 to receive on-demand updates on the status of a beach by 

texting the name of the beach.
National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed. Chapter 5

OPEN: 

*BEACH NAME* is OPEN. To learn more about water quality sampling and the DOH Beach 

Program, go to: http://maps.nyc.gov/beach/. 

ADVISORY; 

WARNING: Swimming and wading at *BEACH NAME* is NOT recommended at this time. 

Water is contaminated with sewage or storm runoff. For more info, text WHY.

CLOSED:

*BEACH NAME* is CLOSED. By Order of the Health Department, swimming and wading 

are not considered safe at this time. For more info, visit: http://maps.nyc.gov/beach/. 

This texting service was accompanied by a media and advertising strategy to promote the 

texting service. Other jurisdictions might wish to consider incorporating texting services into 

their public communication strategies.

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5.4.2 Traditional Mass Media

The news release is the key mechanism for providing notification information to newspapers, 

radio, television, and other traditional media outlets. Some local jurisdictions include beach 

conditions in their weather reports. Risk communicators should treat the news media as another 

target audience to assess and cultivate. The objective is to have the notification content promptly 

published or announced over the air. This is more likely to happen if relationships and protocols 

are established before a beach action. Communicators should learn the informational needs and 

preferences of each media outlet they plan to use, including how it wants the news release 

formatted and delivered to it. That groundwork will help to ensure that notifications are 

published correctly and in a timely manner. 

News releases should be factual, accurate, and carefully proofread. News releases should be 

written with short sentences, using no jargon, and in the active voice. Generally, they should be 

no longer than one page. Where possible, risk communicators should emphasize that a beach 

notification news release is an urgent matter involving public safety. Consider, for example, 

having the local public health agency issue the release instead of a beach administrative office. 

Writing “NEWS RELEASE FOR PUBLIC HEALTH AND SAFETY” and “FOR IMMEDIATE 

RELEASE” in large, bold letters at the top of the news release also helps to emphasize its 

importance.

Some media outlets will publish or announce the news release content exactly as written. Others 

might use only the first one or two paragraphs. Consequently, it is crucial to have the core 

content appear at the beginning of a release, saving the least important information for the end. 

As with a beach sign, risk communicators should present the core content in a style that is 

authoritative and attention-grabbing; for example, “(Named Beach) Closed Because of High 

Bacteria Levels.” The most important secondary content should immediately follow the core 

content. The news release should conclude with the name, title, and contact information of a 

person the media outlet can reach for additional information or clarification. 

5.4.3 Methods that Allow Stakeholders to Anonymously Seek Out Information

Motivated stakeholders who want to learn the current status of a beach should be able to look up 

the information themselves. Websites and hotlines are examples of tools that fulfill this function 

while allowing stakeholders to remain anonymous. Passive information sources like these, 

however, require the risk communicator to develop a marketing effort to publicize and promote 

their use and a plan for continually updating them to keep them current. 

Actively marketing the availability of risk communication resources such as websites and 

hotlines is critical for their success. Stakeholders will need to know the Web address or 

telephone number to use them. That information should be publicized and promoted in as many 

locations as practicable, including the following: 

• All outreach material, such as brochures and newsletters, for the beach program.

• Beach signs and posters. 

• Media outlets, especially those that will receive notification news releases.

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5.4.3.1 Websites

Increased use of the Internet over the past decade has resulted in a corresponding rise in the 

importance of using websites to convey information to the public. All the Great Lakes and 

coastal states, two tribes, and many local jurisdictions maintain websites with beach advisory and 

closing information. The job of the risk communicator is to ensure that a stakeholder seeking 

beach status information can navigate to the beach status page quickly and easily. That can be 

done in several ways, but perhaps the simplest is to provide an eye-catching link on the home 

page that leads directly to a beach status page.

The beach status page should be designed with the idea that readers want to quickly find the 

information they are seeking. Similar to drafting news releases, the core content of any beach 

notification should be up front and prominent. Supplemental information should be less 

prominent but available to support the core content and inform or influence the reader to follow 

the recommendations.

Of all the notification methods, a website provides the best opportunity to present extended 

supplemental information about topics related to beach water quality, public notification, and 

risk communication. For example, on the “Where You Live” Web page 

(http://www2.epa.gov/beaches/state-and-local-beach-programs), each jurisdiction’s name is a 

hotlink to its Web page. Another recommended link is to EPA’s BEACON website at 

http://watersgeo.epa.gov/beacon2/. 

5.4.3.2 Hotlines

For stakeholders who do not use or have access to a computer, a toll-free telephone number 

(hotline) is a method that allows people to quickly and easily obtain information about a beach’s 

status. Like a sign, the recorded content should be brief and to the point. In most cases, only the 

core message can be relayed to the caller, along with where to find more information. 

5.4.3.3 Smartphone Applications

Stakeholders who have smartphones might be able to download an application (app) that will 

give them instant access to water quality conditions at a beach. This technique is being used in 

the Great Lakes states, where an app provides real-time information on public beach conditions, 

including advisories and closures. Beachgoers can identify the beaches closest to them and save 

information on their favorite beaches for future reference. For information about and to 

download the BeachCast app, go to http://glin.net/beachcast/. 

5.4.4 Methods that Rely on Stakeholders to Provide Contact Information to Receive 

Information

Several methods allow a risk communicator to send beach-related messages directly to a 

stakeholder’s computer, email, text inbox, or social networking site. For that to happen, the 

stakeholder should become aware of the service and then take an action to link into the system. 

In addition to marketing the service, the communicator should develop and maintain a 

distribution or subscription list and implement a plan for continually keeping outreach efforts 

current and relevant to stakeholder needs. Emails, text messages, RSS (Real Simple Syndication) 

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feeds, Facebook posts, and Twitter feeds are examples of this form of communication. The link 

to EPA’s BEACON website (http://watersgeo.epa.gov/beacon2/rss.html) is an example of this 

form of communication. 

5.4.4.1 Email

Email is the most popular method of rapidly sending messages through the Internet to designated 

recipients. Recipients can access the message at a time convenient to them and save it if they 

desire. A challenge for the risk communicator is developing and maintaining a list of current 

email addresses. In general, emails should be sent only when there is an important message to 

communicate to stakeholders, such as a beach action. Frequent emails of lower importance might 

cause recipients to routinely ignore them or classify them as spam.

The email message itself should be designed similar to a news release, with the core content up 

front. Other tips include the following: 

• Put the core message in the subject line.

• Keep supplemental messages concise.

• Include the program website address and encourage recipients to visit it for more 

information. 

• Incorporate eye-catching graphics and photos to further enhance or illustrate the message.

5.4.4.2 Text Messages

The use of mobile phones, especially smartphones, is growing every year. Because people keep 

them nearby at almost all times, these devices are becoming popular as an alert system tool. 

Beach notifications, because of their health and safety ramifications, can be perceived as 

important information worthy of a special alert from the beach program. Creating a textmessaging list is similar to creating an email list. Thus, a challenge for the risk communicator is 

to develop a marketing plan to publicize and promote beach action notification through a text 

message alert system.

The text message itself should be concise and focused on core content. Because many phones 

have Internet capability, the message can also provide a link to the beach website, where the 

recipient can get additional information. See the New York City DOHMH case study.

5.4.4.3 Social Networks

Social networking is an evolving phenomenon that allows people to easily communicate with 

others who have similar interests. 

Twitter is a free Web application that allows a user to send messages of up to 140 characters 

(called tweets) to the email addresses or mobile phone numbers of people who have signed up to 

follow the user’s feed. Twitter is versatile, and messages can be composed and sent from 

computers, mobile phones, and other devices. 

Facebook is another social networking tool that lets individuals or organizations communicate 

with one another. Basically, risk communicators can create a beach program profile page and use 

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it to send beach status and other relevant information to a network of Facebook friends. The 

messages show up as newsfeeds on the Facebook pages of recipients. 

As always, to make social media effective as a communication tool, risk communicators should 

undertake a marketing campaign to get stakeholders to sign up for the beach program input. 

Chicago uses a multifaceted approach to communicate with beachgoers—flags, signs, phone 

hotline, website, and social media. Details are provided in the text box below. 

5.4.4.4 RSS Feeds

RSS is a quick and easy way to alert stakeholders of breaking news at a beach. Basically, when 

new information, such as a beach notification, is added to the beach website, the risk 

communicator would also add it to a list on the site’s RSS feed page. People who subscribe to 

the RSS feed would be alerted that new information has been added on the site. They can then 

access it directly by clicking a link that takes them to the appropriate Web page.

5.5 Notification Report Submission (Performance Criterion 8)

Performance criterion 8 requires grant recipients to compile their notification activities and 

report them in a timely manner. States and tribes must report their notification data to EPA at 

least annually. Reported data must be consistent with the database schema for PRAWN found at 

http://water.epa.gov/grants_funding/beachgrants/datausers_index.cfm#notify. The data elements 

include beach description data, beach program data, station and method identification data, and 

beach advisory and closing data. For more information about data submission, see EPA’s

website at http://water.epa.gov/grants_funding/beachgrants/datausers_index.cfm. 

5.6 Delegation of Notification Responsibilities (Performance 

Criterion 9)

Performance criterion 9 requires state grant recipients to describe any delegation of notification 

responsibilities to local governments. States must notify EPA, at least annually, of changes in 

any delegation of responsibilities. EPA encourages states to coordinate with local governments 

and to delegate to local governments, as appropriate, responsibilities for monitoring and 

notification programs. Local governments have traditionally played a lead role in administering 

beach protection programs. 

People at the local level take responsibility for protecting recreational waters for many reasons. 

For example, local citizens and officials often are more familiar with local problems and needs 

and might be in a better position to address local issues and formulate solutions. Also, many of 

the benefits of protecting natural resources—in this case coastal recreation waters—accrue at the 

local level.

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Chicago: Using a Multifaceted Approach to Communicate with Beachgoers

The Chicago Park District (CPD) is responsible for managing 31 beaches in the Chicago area, which 

receive an average of 20 million visitors each summer. CPD launched a multifaceted 

communications campaign for its beach program to better reach a diversity of stakeholders to 

effectively communicate current beach conditions and ways to keep the beach clean.

Flags and signs

For beachgoers already at the beach, CPD uses colored flags to notify the public of water 

quality and weather-related beach conditions. Green indicates no issue reported, yellow 

indicates that a swim advisory is in effect (swimming with caution), and red indicates that 

swimming is prohibited because of severe weather or water conditions that might be 

hazardous. A sign at the beach explains the meaning of the flag color.

Phone hotline and website

CPD uses other methods to notify beachgoers of beach conditions before they go to the beach, 

including a phone hotline (which might reach older beachgoers) and a website (a good source 

for nonresidents).

Social media

Social media were added to CPD’s communications campaign in 2009 as a way to reach out to 

younger beachgoers. The CPD Facebook wall (http://www.facebook.com/ChicagoParkDistrict) 

provides daily beach status updates, posts announcements for events at beaches, and allows 

the public to interact with CPD staff by asking questions or communicating their likes and 

dislikes. The interactive nature of the Facebook site seems to have been well received by the 

public. CPD also sends out announcements using Twitter (http://twitter.com/chicagoparks). In 

2010 CPD launched a new texting service that allows users to receive beach notification 

messages about one or more of the city’s beaches.

Park-and-display service boxes

To reach beachgoers who might otherwise miss or not have access to the various notification 

methods, CPD posts the beach status at the entrance to the beach (before paying for parking) 

with park-and-display service boxes.

CPD has received considerable media attention for its use of novel approaches to reach the public. 

The use of Facebook, Twitter, and the texting service received wide coverage in Chicago media, 

which might have helped raise awareness of the program. Another potential factor influencing 

public interest in the social media tools is the combination of information that CPD communicates. 

For example, CPD’s continuing to post cultural events of interest to the public on its Facebook page 

during winter months when beaches are closed might encourage people to continue to receive or 

sign up for the updates. As of January 2011, CPD had more than 4,000 Facebook friends and 

nearly 2,000 Twitter followers. Between June 7, 2010, when the service was launched, and the 

end of the swimming season in September, about 15,000 text messages were delivered to 

beachgoers at their request. About as many people (12,000 to 15,000) visited the CPD website 

weekly.

In addition to communicating current beach conditions, CPD performs outreach to educate 

beachgoers about how to keep beaches clean. The park staff performs direct outreach by going 

on-site at Chicago’s most popular beaches, encouraging people not to feed gulls and teaching 

them how to properly dispose of litter. The District has also developed a 30-minute cable episode 

to provide similar information.

Information for this case study was obtained from the report Assessing the Effectiveness of the 

Beaches Environmental Assessment and Coastal Health (BEACH) Act Notification Program

(USEPA 2011), which can be found on EPA’s website at 

http://www.epa.gov/evaluate/pdf/beach-act-evaluation-final-report.pdf. 

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5.7 Chapter 5 References

USEPA (U.S. Environmental Protection Agency). 1988. Seven Cardinal Rules of Risk 

Communication. OPA-87-020. U.S. Environmental Protection Agency, Washington, DC. 

———. 1995. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. 

Vol. 4, Risk Communication. EPA 823-R-95-001. U.S. Environmental Protection 

Agency. Washington, DC. 

———. 2011. Assessing the Effectiveness of the Beaches Environmental Assessment and 

Coastal Health (BEACH) Act Notification Program. EPA-100-R-11-004. U.S. 

Environmental Protection Agency, Office of Policy, Washington, DC. 

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Glossary

B 

Beach Action Value (BAV) – The beach notification threshold derived from the 75th percentile 

value on the illness risk distribution for the recommended 304(a) criteria: 32 NGI per 1,000 

recreators and 36 NGI per 1,000 recreators. It is a conservative value used for making beach 

notification decisions (i.e., advisories or closures), and it was introduced in EPA’s 2012 

Recreational Water Quality Criteria. 

Beaches Environmental Assessment and Coastal Health (BEACH) Act – An amendment to 

the CWA passed in 2000. The Act authorizes EPA to provide grants to coastal and Great Lakes 

states, territories, and eligible tribes to monitor their coastal beaches for bacteria that indicate the 

possible presence of disease-causing pathogens and to notify the public when there is a potential 

risk to public health.

BEACH Act beaches – Coastal and Great Lakes beaches or similar points of access used by the 

public for swimming, bathing, or other such activities. 

Beach advisory – Recommendation to avoid swimming at a beach or beach area because of an 

increased risk of contracting a waterborne illness.

Beach Advisory and Closing Online Notification (BEACON) – Database of pollution 

occurrences and notification actions for coastal recreation waters developed and maintained by 

EPA.

Beach closing – Official closure to the public by a state or tribe of a beach or beach area.

Beach use – A factor used to rank beaches in the BEACH Act grant-funded program that refers 

to the usage of the beach by the public. 

Beach notification – An action, such as an advisory or closing, that an agency issues to notify 

the public when a beach has exceeded (or is likely to exceed) an applicable WQS or other beach 

notification threshold. 

Beach notification threshold – A water quality value selected by a state or tribe that is used to 

“trigger” a beach notification. 

C 

Clean Water Act (CWA) – Establishes the basic structure for regulating discharges of 

pollutants into the waters of the United States and regulating quality standards for surface waters. 

The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control 

Act, but the act was significantly reorganized and expanded in 1972. “Clean Water Act” became 

the act's common name with amendments in 1972. 

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Coastal recreation waters – Great Lakes and marine coastal waters (including coastal estuaries) 

designated under CWA section 303(c) by a state or tribe for use for swimming, bathing, surfing, 

or similar water contact activities.

Code of Federal Regulations (CFR) – A codification of the final rules published in the Federal 

Register. Title 40 of the CFR contains the environmental regulations. 

Colony-forming unit (CFU) – A viable cell grown on or in a non-liquid medium culture 

method, where each distinct colony is assumed to be derived from a single viable cell.

Combined sewer overflow (CSO) – A discharge of untreated wastewater from a combined 

sewer system at a point prior to the headworks of a publicly owned treatment works. CSOs 

generally occur during wet weather (rainfall or snowmelt). During periods of wet weather, these 

systems become overloaded, bypass treatment works, and discharge directly to receiving waters. 

Combined sewer systems – A wastewater collection system that conveys sanitary wastewaters 

(domestic, commercial, and industrial wastewaters) and stormwater through a single pipe to a 

publicly owned treatment works for treatment prior to discharge to surface waters. 

D 

Data quality objective (DQO) process – A process used to establish performance or acceptance 

criteria.

F 

Fecal indicator bacteria (FIB) – Bacterial groups or species that are naturally found in the guts 

of warm-blooded animals and excreted in high densities in the feces. They indirectly indicate the 

presence and quantity of fecal pathogens in ambient water. 

G 

Geometric mean (GM) – The mean of the logarithms of recreational water bacterial indicator 

densities in modeling risk attributable to swimming in contaminated waters. 

N 

National Epidemiologic and Environmental Assessment of Recreational (NEEAR) Water 

Study – A collaborative research study between two laboratories of EPA and the Centers for 

Disease Control and Prevention that investigated human health effects and rapid water quality 

methods associated with recreational water use. This study provided real-time water quality 

measurements and helped better understand the link between water pollution, swimming at the 

beach, and peoples’ health. A main goal of the NEEAR study was to determine how new ways of 

measuring water pollution can be used effectively to protect swimmers’ health. 

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National Pollutant Discharge Elimination System (NPDES) – A national program under 

CWA section 402 for regulation of discharges of pollutants from point sources to waters of the 

United States. Discharges are illegal unless authorized by an NPDES permit.

NEEAR GI – A case of gastrointestinal illness within 10 to 12 days of swimming with any of 

the following symptoms: (a) diarrhea (three or more loose stools in a 24-hour period); (b) 

vomiting; (c) nausea and stomachache; or (d) nausea or stomachache and impact on daily 

activity. NEEAR GI is the definition associated with EPA’s 2012 Recreational Water Quality 

Criteria. 

Non-program beaches – BEACH Act beaches not in a state’s or tribe’s current monitoring and 

notification program, including beaches not monitored because of fiscal constraints.

P 

Pathogen – Microorganisms that have the potential to cause disease in a host.

Pathogen indicator – A substance that indicates the potential for human disease as defined by 

the BEACH Act (33 U.S.C. 1362(23). Pathogen indicator is a broad category of entities 

(including chemical and biological parameters) that can be used to indicate the presence of 

pathogens in water. 

Predictive tools – Statistical regression models, rainfall-based notifications, decision trees or 

notification protocols, deterministic models, or any combination of these tools used to predict an 

exceedance or likely exceedance of a WQS or other notification threshold value. 

Primary contact recreation – Recreational activities where immersion and ingestion are likely 

and there is a high degree of bodily contact with the water, such as swimming, bathing, surfing, 

water skiing, tubing, skin diving, water play by children, or similar water-contact activities.

Program beaches – BEACH Act beaches subject to a state’s or tribe’s BEACH Act monitoring 

and notification program, consistent with the performance criteria.

Publicly owned treatment works (POTWs) – Wastewater treatment works owned by a state or 

municipality (as defined by CWA section 502(4)) that include any devices and systems used in 

the storage, treatment, recycling, and reclamation of municipal sewage or industrial wastes of a 

liquid nature. It also includes sewers, pipes, and other conveyances only if they convey 

wastewater to a POTW. 

Q 

Quantitative microbial risk assessment (QMRA) – A formal process, analogous to chemical 

risk assessment, for estimating human health risks due to exposures to selected infectious 

pathogens. 

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Quantitative polymerase chain reaction (qPCR) – A genetic test used to quantitatively 

determine the amount of DNA template in a sample relative to a standard.

R 

Recreational Water Quality Criteria – CWA sections 304(a) and 304(a)(9) recommendations 

issued by EPA as guidance to states, territories, and authorized tribes in developing WQS to 

protect swimmers from exposure to water that contains organisms that indicate the presence of 

fecal contamination. 

Risk – A factor used to rank beaches in the BEACH Act grant-funded program that refers to the 

susceptibility of a beach to fecal contamination.

S 

Sanitary sewer overflows – Untreated or partially treated sewage overflows from a sanitary 

sewer collection system.

Sanitary survey – Detailed site characterization that compiles information on pollution sources 

(such as streams or stormwater outfalls) at a beach, physical features on or near a site, land use in 

adjacent areas and in the watershed that drains to the site, and other sources that could regularly 

influence water quality.

Statistical Threshold Value – Approximates the 90th percentile of the water quality distribution

for the 2012 RWQC and is intended to be a value that should not be exceeded by more than 10 

percent of the samples taken for assessment and listing purposes. 

T 

Tier 1 beaches – Highest priority beaches because of high risk and/or high use.

Tier 2 beaches – Beaches with high or moderate use and moderate or low risk. 

Tier 3 beaches – Beaches with low use and low or very low risk. 

Tiered monitoring plan – Plan that addresses the frequency and location of monitoring and the 

assessment of coastal recreation waters on the basis of the periods of recreational use, the nature 

and extent of use during certain periods, the proximity of recreational waters to known point and 

nonpoint sources of pollution, and the effect of storm events.

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