13 replies to this topic

[ewhite]

Our water quality program has become an area of constant critique, and cause of headache as it seems we cannot develop an appropriate program.

Facts:
- We use water as a main ingredient in our products.
- We receive water from the city, and they provide us with yearly reports.
- We have well water that is used only as cooling tower water.
- We receive quarterly reports from a state lab (We pasteurize milk products (rehydrated NFDM) once a month, and therefore have a state inspector that comes quarterly submitting water samples from our main supply, well and glycol)
- We test our well water and city water weekly for P/A of coliforms and E.coli
- We conduct weekly Free Chlorine tests before and after our filter to verify it is adequately removing the chlorine from the city.
- I've attached a modified verision of our current program, and I would like some input, as it seems to always trigger questions from our auditors.

Additionally, could someone help with corrective actions?

Thank you!!
Erika

Attached Files

•  Water Quality Program.doc   30.5KB   405 downloads

Edited by ewhite, 15 April 2011 - 04:41 PM.

[Cathy]

Can you clarify what the noncompliance was or is this a generalized concern?
One thing possibly not stated clearly enough is that water lines for potable and non-potable water do not and can not intersect.
Also - a common problem is that water samples are not always taken at the point of use (for water as an ingredient). If you also state and do this, it may help.

[Dr Ajay Shah]

I totally agree with the comments made by Cathy. One must check for conducting water microtesting at point of source in the processing area where water is either used for cleaning or as part of adding to the food as an ingerdient.

Ajay

[cosmo]

Our water quality program has become an area of constant critique, and cause of headache as it seems we cannot develop an appropriate program.


I've attached a modified verision of our current program, and I would like some input, as it seems to always trigger questions from our auditors.

Additionally, could someone help with corrective actions?

Thank you!!
Erika

Erika,
First what questions do the auditors ask, and are the corrective actions for ineffective water treatment?
Regards Cosmo

[ewhite]

Erika,
First what questions do the auditors ask, and are the corrective actions for ineffective water treatment?
Regards Cosmo

Thank you all for the comments!
One specific concern is that we have documented positive results in the past, for coliforms at a spigot near the batch area. Because we usually take the samples during processing we do not take the water sample from the tank were it is added to the product. However I suppose this is what you are reccommending. Upon reading the positive results we retook the sample from the same location as well as a random location from the same city supply (specifically in this case from a handwash sink in the plant). The results from the sink came back negative, but the initial location came back positive. We had our cleaning crew clean this spigot and retested to produce two consecutive negative results from the original location, and then returned to weekly testing.
I am open to suggestions on better ways to handle this situation as we still are working on documenting a corrective action procedure for positive test results.

On a side note, I think we should have handled this differently, as I know it raises questions about why we didnt establsih corrective actions earlier.
However, the microbiology for our finished products always tested as <10 MPN Coli. & <1 MPN for E.coli, and since I've had a really hard time finding a concise answer on what's required for water used in food products, this has turned into an extended work in progress issue. We've since replaced the problemed spigot (which was threaded) to a smooth surface pipe, and haven't had positive results since. Considering that I can't change past results, what are some reccomendations for moving forward?

Thank you for the help!!

Edited by ewhite, 25 April 2011 - 08:23 PM.

[Charles.C]

Dear ewhite,

I wonder how many people here knew what a spicket is ? Not me for sure.
Or even a spigot if it comes to that ?(= spicket apparently)

I am rather amazed that yr local food regulations do not require you to do any chemical analyses unless this is somehow covered in the “reports” you initially mentioned.

I am equally sure yr query regarding the specific microbiological requirements for the water in use must also surely be defined in same local regulations.

As far as sampling of water is involved, I think it is typical to (perhaps rotationally) sample from the external input supply(s), possibly from the output(s) of any subsequent filtration stages and then from selected positions within the manufacturing facility. The details will depend on yr actual distribution network. Ideally a risk assessment is required.

Rgds / Charles.C

I deduce that all the water in use in yr plant is chlorine-free. The local bacteria must love you.

[ronaldb]

One of the things that can throw up positive results is dead legs in the pipe works. These can be in the form of outlets blanked off because they are no longer in use or you may have had a leak and that part of the line was switched off. Over a period of time, bacteria will accumulate in these areas and small amounts will be "pulled" out by the normal flow.

[MKRMS]

To add to this lively discussion: the easiest way to avoid stagnant water (see above, post by rondaldb) from dead pipe systems getting into food production is to draw water that is to be used in food production as close to the municipal mains as possible. This means that a direct supply pipe without any other drawing points or cross-connections should run from the earliest possible drawing point after the municipal pipe exchange to the food production line. Downstream water should then be used for housekeeping (e.g. cleaning, hand washing, flushing toilets, etc in the order of food safety relevance). I like the fact that you have vacuum-breaker valves installed that prevent backflow of potentially contaminated water into the system.
In your Water Quality Program, I am missing mentioning of the fact that the two water systems (well water for cooling, city water for production) are physically separated and drawing points that serve well water either do not exist in food preparation areas or are clearly marked as not to be used for food preparation. In my opinion, it is irrelevant if your well water is potable if it is only used to condensate refrigerant (heat exchange) without food contact and I would not include the well water under the heading of potable water at all, unless you plan to use it (or are actually using it) in food production. This could simplify matters considerably and avoid misunderstandings.

As far as corrective action is concerned, there are a number of possible actions to take: (a) treatment of municipal or well water on site (chlorination, UV) if municipal supply is not safe, (b) shut-off of municipal supply if found unsafe. In both cases, subsequent product testing would be necessary to establish safety of produce and product withdrawal or recall might be indicated.
To avoid production downtime, a contingency supply should be identified in case of the public water supplies becoming unsafe. Your well might give you an advantage here. Regular (minimum monthly, better weekly) microbiological and chemical monitoring and adequate treatment is needed if you want to use your well as a backup supply of potable water.

Also, I agree with Charles.C, water can become unsafe through chemical contamination as well as biological contamination. Your Programme makes no reference to this. In Europe, it is generally acceptable to rely on public water analysis and regard the municipal supply as being safe, but in case of an incident, the buck still stops with the food business operator, so regular in-house testing is always advisable.

I would query your limits for total coliforms and faecal coliforms at <10. I would expect these to be <1 for drinking water.

[Tony-C]

Our water quality program has become an area of constant critique, and cause of headache as it seems we cannot develop an appropriate program.

Facts:
- We use water as a main ingredient in our products.
- We test our well water and city water weekly for P/A of coliforms and E.coli

Additionally, could someone help with corrective actions?

Thank you!!
Erika

Hi Erika

You should test your water daily as it is an ingredient.

Kind regards,

Tony

Edited by Tony-C, 21 April 2011 - 12:55 AM.

[chai]

i think its better also if you have an SSOP KSA1-Safety of Water Supply.

[Charles.C]

Dear ewhite,

Any further comments ?

Rgds / charles.C

[ewhite]

i think its better also if you have an SSOP KSA1-Safety of Water Supply.

Could you elaborate on what a SSOP KSA1-Safety of Water Supply is? I get the SSOP part, but does the KSA1 part have any special meaning?
Thanks!

[ewhite]

Dear ewhite,

I wonder how many people here knew what a spicket is ? Not me for sure.
Or even a spigot if it comes to that ?(= spicket apparently)

I am rather amazed that yr local food regulations do not require you to do any chemical analyses unless this is somehow covered in the “reports” you initially mentioned.

I am equally sure yr query regarding the specific microbiological requirements for the water in use must also surely be defined in same local regulations.

As far as sampling of water is involved, I think it is typical to (perhaps rotationally) sample from the external input supply(s), possibly from the output(s) of any subsequent filtration stages and then from selected positions within the manufacturing facility. The details will depend on yr actual distribution network. Ideally a risk assessment is required.

Rgds / Charles.C

I deduce that all the water in use in yr plant is chlorine-free. The local bacteria must love you.

My appologies for the confusion with spickets, spigots and other faucet like outlets.... Anyways, the "reports" include chemical and micro analysis, submitted by the city. The criteria that I have for my "local regulation" is the Maximum Contaminant Parameters from the city.

As for the actual sampling, would it be appropriate to sample from the most critical sites daily, and the external input supplies, outputs, and subsequent filtration steps on a weekly or monthly basis (assuming our risk assesment doesn't flag any of these?)

[Charles.C]

Dear ewhite,

Thks for reply.

As for the actual sampling, would it be appropriate to sample from the most critical sites daily, and the external input supplies, outputs, and subsequent filtration steps on a weekly or monthly basis (assuming our risk assesment doesn't flag any of these?

)

I would initially suggest you pursue the same method you are (Contaminant) quoting for your "local regulation". Which is ??

Rgds / Charles.C