Most probable number (MPN) and colony-forming-unit (CFU) estimates of fecal coliform bacteria concentration are common measures of water quality in coastal shellfish harvesting and recreational waters. Estimating procedures for MPN and CFU have intrinsic variability and are subject to additional uncertainty arising from minor variations in experimental protocol. It has been observed empirically that the standard multiple-tube fermentation (MTF) decimal dilution analysis MPN procedure is more variable than the membrane filtration CFU procedure, and that MTF-derived MPN estimates are somewhat higher on average than CFU estimates, on split samples from the same water bodies. We construct a probabilistic model that provides a clear theoretical explanation for the variability in, and discrepancy between, MPN and CFU measurements. We then compare our model to water quality samples analyzed using both MPN and CFU procedures, and find that the (often large) observed differences between MPN and CFU values for the same water body are well within the ranges predicted by our probabilistic model. Our results indicate that MPN and CFU intra-sample variability does not stem from human error or laboratory procedure variability, but is instead a simple consequence of the probabilistic basis for calculating the MPN. These results demonstrate how probabilistic models can be used to compare samples from different analytical procedures, and to determine whether transitions from one procedure to another are likely to cause a change in quality-based management decisions.