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Guitardr85

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Posted 09 October 2017 - 01:40 PM

Good Morning fellow Food Safety Warriors,

 

I am having an issue that I have not encountered before and I was hoping to get a little feedback on as to some corrective actions (those involving capex are welcomed :) )

 

We have recently been encountering elevated APC counts in our water supply.  I have eliminated the possibility of sampling error and point of use contamination so the issue is either within the pipes/treatment system or from the municipal water facility itself.  

 

It is worth noting that I am in a low risk facility and the water is used for GMP practices (hand washing) and sanitation in a dedicated wash room area for direct food contact instruments and parts.  This issue has not migrated to any other locations (verified through sampling) but I really want to knock this out at the source.  Has anyone run into a similar issue as this or have any suggestions as how to correct this.

 

Looking forward to the feedback and questions!!!



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Posted 09 October 2017 - 02:46 PM

First, what's "elevated"? There's no standard of quality for HPC in municipal water supplies, so where's it at, where do you want to see it, and why?

 

I'd see if you can sample from another faucet at a neighboring business/residence, then you can establish whether the counts are being distributed from your water provider or if they are somehow increasing within your plant's distribution system.


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Charles.C

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Posted 10 October 2017 - 02:29 AM

Good Morning fellow Food Safety Warriors,

 

I am having an issue that I have not encountered before and I was hoping to get a little feedback on as to some corrective actions (those involving capex are welcomed :) )

 

We have recently been encountering elevated APC counts in our water supply.  I have eliminated the possibility of sampling error and point of use contamination so the issue is either within the pipes/treatment system or from the municipal water facility itself.  

 

It is worth noting that I am in a low risk facility and the water is used for GMP practices (hand washing) and sanitation in a dedicated wash room area for direct food contact instruments and parts.  This issue has not migrated to any other locations (verified through sampling) but I really want to knock this out at the source.  Has anyone run into a similar issue as this or have any suggestions as how to correct this.

 

Looking forward to the feedback and questions!!!

 

Hi Guitar,

 

As per previous post some quantitative data may assist.

 

I imagine you also hv some coliform/E.coli data which are I believe typically monitored in USA (EU for "process" water initially usually focuses on APC/coliform/Ecoli and does suggest limits).

 

If the water is chlorinated (??) APC levels shud be "low".


Kind Regards,

 

Charles.C


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Posted 12 October 2017 - 01:28 PM

Thank you for your responses.  I should have added that we are looking at APC levels as this is part of our corporate policy (this would be elevated by our standards). Our APC level results have been fluctuating between 50 and 2500cfu/g. Additionally, all other pathogen testing results have been negative (e.g. E. coli).

 

If we determine that this is either municipal or a piping issue, has anyone had experience with filtering/treatments systems for water?



FurFarmandFork

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Posted 13 October 2017 - 03:49 PM

There's a million resources out there for on-site water treatment. It's expensive setup but then relatively easy maintenance.

 

2500 is pretty high for a chlorinated municipal source, but not unreasonable for a "first draw" sample. Non-sterile bottled water can typically have a "bloom" after bottling that takes it up to 6 log before dieing off.

 

To evaluate source vs your plant, it might be worth getting more data on "first draw" vs after a hose/faucet has been running for 15 minutes.

 

I maintain that if your water is only used for sanitation then your sanitizing step would take care of any small number of organisms introduced by your rinse step, and more importantly would be that your water was free of "organisms of concern".


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Posted 14 October 2017 - 01:48 AM

Hi Guitar,

 

The only US "Guideline" I could see has -
 

 

HPC: NO more than 500 bacterial colonies per milliliter

 

HPC = Heterotrophic Plate Count

 

http://www.water-res...imary-standards

 

Is the water chlorinated ?, ie has a detectable ppm of free Cl2


Kind Regards,

 

Charles.C


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Posted 15 October 2017 - 12:58 AM

Hi Guitar,

 

The only US "Guideline" I could see has -
 

 

HPC = Heterotrophic Plate Count

 

http://www.water-res...imary-standards

 

Is the water chlorinated ?, ie has a detectable ppm of free Cl2

 

That figure is not a regulatory standard, just a guideline by some consultant group...of course they recommend some lower levels. Helps them sell more services.... :)

 

As far as the OP is concerned I'm wondering why they are even concerned with this?  If the water is not used as an ingredient after some type of process kill step and you are sanitizing your equipment at end of cleaning this shouldn't be an issue or even evaluated.

 

I would say the only concern would be rinsing down production equipment where there is food contact WITHOUT sanitizing after rinsing?  



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Posted 15 October 2017 - 02:34 AM

That figure is not a regulatory standard, just a guideline by some consultant group...of course they recommend some lower levels. Helps them sell more services.... :)

 

As far as the OP is concerned I'm wondering why they are even concerned with this?  If the water is not used as an ingredient after some type of process kill step and you are sanitizing your equipment at end of cleaning this shouldn't be an issue or even evaluated.

 

I would say the only concern would be rinsing down production equipment where there is food contact WITHOUT sanitizing after rinsing?  

 

Hi Ryan,

 

The US EPA is merely a "consultant group" ?? I sincerely hope not.

 

Attached File  National Primary Drinking Water Regulations _ Ground Water and Drinking Water _ US EPA.pdf   60.46KB   35 downloads

 

Although not so far discussed, i assume water as referred in OP (Municipal Authority) is intended to be of a "Quality" considered directly "suitable" for Drinking (?) (Safety is not necessarily identical to "Quality" of course).

 

As previously noted, the internal piping system may simply have caused contamination. A Non-detectable free-chlorine (eg <0.1 ppm) might be interesting unless this is not relevant to US Municipal water supplies (eg ultrafiltration processes ?)

 

PS - I note that the EPA's textual use of the word "contaminant" is IMO questionable.


Kind Regards,

 

Charles.C


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Posted 15 October 2017 - 03:24 AM

Hi Ryan,
 
The US EPA is merely a "consultant group" ?? I sincerely hope not.
 
attachicon.gifNational Primary Drinking Water Regulations _ Ground Water and Drinking Water _ US EPA.pdf
 
Although not so far discussed, i assume water as referred in OP (Municipal Authority) is intended to be of a "Quality" considered directly "suitable" for Drinking (?) (Safety is not necessarily identical to "Quality" of course).
 
As previously noted, the internal piping system may simply have caused contamination. A Non-detectable free-chlorine (eg <0.1 ppm) might be interesting unless this is not relevant to US Municipal water supply (eg ultrafiltration process ?)
 
PS - I note that the EPA's textual use of the word "contaminant" is IMO questionable.


US EPA mandates coloform levels not HPc levels. Where in that standard does it reference a requirement for HPC? On the website you had linked it was from a consultant group.

If there is a regulation for HPC from EPA that’s news to me...and a lot of places haven’t been monitoring it for quite some time here in the states.


Ryan M.

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Posted 15 October 2017 - 03:26 AM

Hi Ryan,
 
The US EPA is merely a "consultant group" ?? I sincerely hope not.
 
attachicon.gifNational Primary Drinking Water Regulations _ Ground Water and Drinking Water _ US EPA.pdf
 
Although not so far discussed, i assume water as referred in OP (Municipal Authority) is intended to be of a "Quality" considered directly "suitable" for Drinking (?) (Safety is not necessarily identical to "Quality" of course).
 
As previously noted, the internal piping system may simply have caused contamination. A Non-detectable free-chlorine (eg <0.1 ppm) might be interesting unless this is not relevant to US Municipal water supply (eg ultrafiltration process ?)
 
PS - I note that the EPA's textual use of the word "contaminant" is IMO questionable.


Read the PDF standard you just posted...it states N/A because HPC is not a health standard.


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Posted 15 October 2017 - 03:28 AM

Read the PDF standard you just posted...it states N/A because HPC is not a health standard.

 

Please read the footnotes.


Edited by Charles.C, 17 October 2017 - 07:49 AM.
edited

Kind Regards,

 

Charles.C


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Posted 15 October 2017 - 03:34 AM

Please read the footnotes.


You realize that the footnotes apply to treating groundwater and surface water right? Not related to drinking water standards....

Completely different Charles. You are stretching..

Again...EPA has no requirements for HPC limits on drinking water. It shows in this standard. If there was a requirement it would be stated in the past initial limits like with everything else, not in the footnotes.



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Posted 15 October 2017 - 03:47 AM

You realize that the footnotes apply to treating groundwater and surface water right? Not related to drinking water standards....

Completely different Charles. You are stretching..

Again...EPA has no requirements for HPC limits on drinking water. It shows in this standard. If there was a requirement it would be stated in the past initial limits like with everything else, not in the footnotes.

 

Hi Ryan,

 

No problem. We can agree to differ.

 

The interesting OP datum will be the HTC level at official point of delivery. i anticipate << 2500 cfu/gm


Kind Regards,

 

Charles.C


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Posted 18 October 2017 - 06:45 AM

The usage of HPC data in a drinking water context is apparently complicated and subjective. Some Countries use it for Regulatory/specific products, eg bottled drinking water, others use it more for assessing water treatment efficiency.

 

The 5 following links/attachments hopefully give a little detail  on the US situation -

 

(1) Historical up to 2003

12.6.6  Regulations in the USA

Regulations  for  drinking-water  quality  from  both  private  systems  and  public water utilities in the USA are provided by the US EPA. Drinking-water is under federal jurisdiction, so these regulations are enforceable across the country.

In  the  USA,  acceptable  HPC  levels  in  municipal  drinking-water  have  been set at less than 500 cfu/ml. Historically, as is the case in Canada, this level was recommended  because  higher  colony  counts  interfered  with  the  detection  of total  coliforms  in  lactose-based  tests.  During  the  development  of  the  Surface Water  Treatment  Rule,  it  was  decided  that  maintaining  an  HPC  concentration below  the  allowable  500  cfu/ml  limit  could  be  used  as  a  substitute  for maintaining  a  detectable  disinfection  residual  (US  EPA  1989).  More  recently, the  US  EPA’s  National  Primary  Drinking  Water  Standards  (US  EPA  2001) express HPC as a method of measuring the variety of bacteria present in a water sample but with no health significance. In this secondary standard, no maximum contaminant  level  goal  is  set,  but  the  maximum  contaminant  level  is  still  500 cfu/ml. This is not an enforceable federal standard.

 

Other  agencies,  such  as  the  American  Water  Works  Association,  have  not recommended  an  operating  level  or  goal  for  HPC  bacteria  in  drinking-water. They  do  recommend  minimizing  HPC  levels  in  water  leaving  the  treatment plant  and  for  water  in  the  distribution  system.  It  is  suggested  that  each  utility should establish baseline data for their water source based on at least two years of sampling of plant effluent, points of mean residency time in the distribution system  and  problem  areas,  such  as  dead-end  reservoirs  and  sites  downstream from pressure-reducing valves (AWWA 1990).

 

In   the   USA,   bottled   water   is   monitored   by   the   Food   and   Drug Administration, and no HPC standards have been established (FDA 2001).

 

(Note1 - The AWWA viewpoint may now hv changed somewhat, eg this 2015 quote -

Attached File  HPC-AWWA.png   37.55KB   0 downloads

(Note 2- Regarding EPA, see (3) below for present scenario.[newer technology reduces the interference aspect]

 

(2) A more recent  article (2016) presenting a quite readable "update" from a (unusual) POV –

Attached File  HPC - health concerns,2016.pdf   501.07KB   19 downloads

 

(3) EPA’s general opinion on HPC in drinking water

https://safewater.ze...drinking-water-

 

 (4) Missouri’s interpretation/implementation of EPA’s Guidelines

http://health.mo.gov...picbacteria.php

 

(5) Although not USA-specific, this detailed analysis on the Canadian Gov. website of a situation quite similar to that in OP is well presented IMO.

https://www.canada.c...r-supplies.html

 

Further analysis will probably require data such as mentioned in Posts 6, 13.


Kind Regards,

 

Charles.C




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