Back to the Basics: Water

Perhaps the most publicized and recognized pioneer epidemiological work was with the infamous cholera outbreaks in London. The 1854 outbreak inspired Dr. John Snow to trace the most probable source to the publically used water pump on Broad Street. Based on his findings, the pump handle was removed; however, little was understood about microbiological risks associated with water.

Since then, modern technology and studies have identified water as a key transmission agent for pathogens, including noroviruses, E. coli O157:H7, Cryptosporidium; toxins from aquatic microorganisms, such as cyanobacteria; organic and inorganic chemicals (benzene, pesticides, arsenic and nitrates; lead and copper; disinfection byproducts or DBPs such as trihalomethanes); and radioactive compounds.⁽¹⁾

ONGOING & EMERGING CONCERNS
Problems with the source.
Since the passing of the Safe Drinking Water Act in 1974 (with subsequent amendments), Americans have a justifiable comfort level with the water that comes from their taps. Notable exceptions have occurred, such as the March 2010 “boil order” for the City of Boston and surrounding communities, which affected approximately two million consumers and an unknown number of food and beverage manufacturing locations.

Manufacturing locations need to have a documented contingency plan for the appropriate actions to follow if notified the water is not potable. The plan should include a comprehensive review of water-usage throughout the facility, including water used to manufacture product and ice, wash utensils and equipment, wash hands, and drink (including vending machines that use water or ice). The plan also needs to include an assessment of the safety of product that was manufactured before the plant was notified of the water safety concerns.

If deemed necessary, identify an alternative source and delivery method of emergency water, ensuring that both the source and transporter meet the EPA and FDA requirements, including the potable water certificate, tank wash tags, and so forth.

Additional items to consider in response to a notification that the water does not meet potable water requirements have been provided by the FDA in their “Guidance for Industry: Use of Water by Food Manufacturers in Areas Subject to a Boil-Water Advisory.” This guidance augments the Retail Food Guidelines used by most state regulatory agencies for both retail and wholesale manufacturers. The food manufacturers’ guidelines can be found online by searching the above title or click here.

In-house protection of water.
Water plumbing, including design, construction and materials, is a complex science that must take into consideration the demand within the facility (sufficient water supply/size of the water line to the facility), pressure differentials, materials (NSF/ANSI Standards), and appropriate protection from possible contamination through back-siphoning/backflow or the direct injection of chemicals into the line.

The National Plumbing Code is the baseline standard in the United States, which can also be stricter, based on state and local regulations. Most states require that all modifications to a water system be made by a licensed plumber. If this is not a requirement in your area, the use of a licensed plumber is highly recommended; at a minimum, any modifications to the water system should be reviewed by a licensed plumber.

Creative water re-use.
An emerging concern is that, with an ever-growing population, water is becoming a scarce resource, as evidenced by “water wars” between countries and states. In response to an increasing demand, alternative sources, treatments and recycle/re-use have been developed without being fully understood, controlled or maintained.

Before re-using water in a food or product contact manufacturing location, validate that the use, treatment and ongoing monitoring meets regulatory requirements, recognized standards of the industry and/or recognized expertise (such as a university study, USDA extension service guidelines, or other science-based information).

POTABLE WATER SOURCE
FDA regulations.
FDA’s Good Manufacturing Practices (GMP) regulation 21CFR Part 110 states that all food process water must be safe and suitable for its intended use, specifically:

• Part 110.37(a) Facilities, Water Supply: “The water supply shall be sufficient for the operations intended and shall be derived from an adequate source.”
• Part 110.80, (a)(1) Processes and Controls, Raw Materials and Other Ingredients: “...Water used for washing, rinsing, or conveying food shall be safe and of adequate sanitary quality....”)

The FDA and USDA recognized the U.S. Environmental Protection Agency’s (EPA) standards (40 CRF Part 141) for safe drinking water as adequate sanitary quality.

PRODUCT SAFETY CONCERNS
The EPA has developed a list of contaminants (biological, chemical and radiological) and their maximum acceptable levels for drinking water.⁽²⁾ These potential contaminants are routinely tested by the municipal supplier. If your facility is using a privately-owned and operated system, the FDA requires that the water meet the same safety parameter standards and testing.

To ensure that your facility’s water meets the EPA requirements for safe water, obtain the potable water certificate from your supplier. The EPA requires that the average of the supplier’s annual test results, as well as any results that do not meet the EPA standards, must be provided to the users. For a privately-owned source (vs. a municipal system), the same tests and standards are required. The results must be reviewed by the food/food contact packaging manufacturer to verify that the water is in compliance.

A recommendation is to collect and test the water at your point-of use for Total Plate Count and coliform. The purpose of this additional testing is to ensure the water system in your facility has not been contaminated. Based on the complexity of your water system, approximately three to five samples should be collected every three to six months. Use an EPA-accredited water testing laboratory and let the laboratory know that you have chlorinated water so that the appropriate test container is used (typically contains a chemical that will neutralize the chlorine).

PRODUCT QUALITY CONCERNS
National Secondary Drinking Water Regulations are non-enforceable guidelines for contaminants that may cause aesthetic effects (such as taste, odor or color) in drinking water. The EPA recommends, but does not require, that the water be tested for these secondary standards. States may choose to adopt them as enforceable standards. Review the standards to note if any could adversely affect your product and, if not tested by your source, add to your in-house sampling schedule.

Other water characteristics, such as pH, hardness, color, flavor, etc., can directly affect the functionality of your raw materials and finished product characteristics. Work with your Research and Development team, suppliers, equipment manufacturers, and literature review to identify water characteristics that are key to your product and process.

Pseudomonas spp.
Pseudomonas has been directly linked to food spoilage and decreased shelf life as well as the development of biofilms. This organism can grow at a wide temperature range and has been directly linked to spoilage of dairy products (including milk, cottage cheese, cheese), eggs, meat, fish^{(3, 4, 5)} and beer. Although P. aeruginosa is of increasing concern in hospitals, food is not a source of this organism for these immune-suppressed individuals.

In-plant water treatment and delivery systems may actually encourage the growth of Pseudomonas since the organism likes to adhere to the walls of piping systems, inside filters (especially carbon filters, which provide a food source), and on other surfaces; the growth can develop to such a level where it can develop a biofilm. If Pseudomonas is of concern at your facility or to your products, recommendations are to ensure the water is in continuous motion (recirculate at a flow velocity of two to seven feet per second) and that filters, especially carbon and membrane filters are frequently changed or back-flushed⁽⁶⁾.

CONCLUSION
Our knowledge of the critical nature of safe, legal, and quality water has significantly expanded since Dr. Snow removed the pump handle, with resulting federal and state regulations to ensure safe potable water. However, if we are not diligent in monitoring the source, as well as the design, materials and construction of the delivery system, this frequently overlooked resource can have tremendous repercussions to the safety and quality of the products being made.

The author is HACCP Coordinator, AIB International.

(1) Committee on Public Water Supply Distribution Systems: Assessing and Reducing Risks, National Research Council; Drinking Water Distribution Systems: Assessing and Reducing Risks, 2006, pg 88.

(2) http://www.epa.gov/safewater/contaminants/index.html.

(3) Pereira, JN, and Morgan, ME (1957 Dec). “Nutrition and physiology of Pseudomonas fragi.” J Bacteriol 74 (6): 710–3. PMID: 13502296 ).

(4) Levine, M, and Anderson, DQ (1932 Apr). “Two New Species of Bacteria Causing Mustiness in Eggs.” J Bacteriol 23 (4): 337–47. PMID 16559557.

(5) Gennari, M, and Dragotto, F (1992 April). “A study of the incidence of different fluorescent Pseudomonas species and biovars in the microflora of fresh and spoiled meat and fish, raw milk, cheese, soil and water.” J Appl Bacteriol 72 (4): 281–8. PMID 1517169.

(6) “Pseudomonas In Purified Water, Spas and Drinking Water Systems,” APS Water.