24 replies to this topic

[GMO]

Issue 6, section 4.5.1; The microbiological and chemical quality of water shall be analysed at least annually.

Do you test your water chemically as well as microbiologically? Is the water supplier's testing for chemical contaminants sufficient? (They refuse to publish results in my area until the full calendar year has passed and then they take 6 months to publish the summary, so, in March 2012, i will be able to tell my auditor the chemical safety was fine throughout 2010... Helpful. )

Section 4.5.4; Air, other gases and steam used directly in contact with or as an ingredient in products shall be monitored to ensure this does not represent a contamination risk.

How do you monitor steam? Any ideas?

[SQFconsultant]

Issue 6, section 4.5.1; The microbiological and chemical quality of water shall be analysed at least annually.

Do you test your water chemically as well as microbiologically? Is the water supplier's testing for chemical contaminants sufficient? (They refuse to publish results in my area until the full calendar year has passed and then they take 6 months to publish the summary, so, in March 2012, i will be able to tell my auditor the chemical safety was fine throughout 2010... Helpful. )

Section 4.5.4; Air, other gases and steam used directly in contact with or as an ingredient in products shall be monitored to ensure this does not represent a contamination risk.

How do you monitor steam? Any ideas?

Testing for chemical and micro. The Auditor is going to be looking for your testing report and not the local test water authority testing report. Don't expect your Auditor to accept a verbal "everything is fine with the water" message.


On steam you would provide methods for monitoring/corrective actions, etc. Steam source being water could be as simple as steam sampling and sending out/or in-house lab for analysis. Ensuring steam tips are clean, etc. Swab testing could be another method in the concentrated area for steam.


Great faces by the way!

[GMO]

Testing for chemical and micro. The Auditor is going to be looking for your testing report and not the local test water authority testing report. Don't expect your Auditor to accept a verbal "everything is fine with the water" message.

Ha, ha, ha! Yes, I wasn't expecting that! My point was, what 'chemical' should I be testing for? I presume giving them results from 15 months ago from my water authority would not be adequate but even I, as an ex chemist am struggling to think "what should I test for?" as the list could be almost endless! The local water authority's list lasts several pages! Is there an 'indicator' chemical I should test for which would indicate an issue with the supply or with our system?

On steam you would provide methods for monitoring/corrective actions, etc. Steam source being water could be as simple as steam sampling and sending out/or in-house lab for analysis. Ensuring steam tips are clean, etc. Swab testing could be another method in the concentrated area for steam.

So, I'm interested, how do you sample steam from inside a travelling oven? How do you swab? "As simple as steam sampling." I'd like to see the H&S risk assessment for that one! How do I condense it? What am I testing it for? What's the point in micro testing?

[Bawdy]

To hopefully help answer the question regarding steam testing - I used to work in a cannery where we had to do steam sampling and testing as per the BRC requirement.

Fortunately we had a few long steam pipes that would cool the first part of the steam and cause it to condense back to water, allowing us to collect it. It was standard practice to open the pipe/valve and run the steam until it had blown the condensed water out to ensure full steam to the relevant section of the factory/equipment. If you were quick, you could catch some of the first condensate before it got too hot.

Occasionally we could collect the condensed steam water the next day, if the operators shut off the valves in the right sequence, we could "capture" some steam, wait for it to cool then simply open the valve and collect the water as it ran out, in fact many prefered this method to avoid any potential OH&S issues.

We would then test this water for pH and conductivity, using simple meters in the lab, clarity (visually assesed) and taste/aroma. If it gave similar results to the potable town water, then we said it was good. Did not test for micro, what would be the point, what is going to survive inside saturated steam?

We did this every 3 months, kept records of course. Auditors were happy with this response/approach, never had a NCR raised against it.

Incoming water testing was a standard practice for our lab, we tested daily, but only pH and conductivity and did a visual assesment. Every three months we did an in house e.coli, TPC and coliforms test/count using the 3M Petrifilm product. Again auditors were happy with this.

Hope this helps.

Bawdy.

[GMO]

Thanks for your help. It's one of those bizarre things that I'm not sure pH would make a jot of difference to our product anyway and I'd be testing it for the sake of testing!!! Still a pH probe might be an idea. How do you test conductivity? It's been a while since I was a chemist!

Btw, for info, we make bread.

[Bawdy]

Hi GMO,


I understand that pH may not be a critical parameter for you to measure on your product, but it is a good indicator for changes in your water quality. I wouldn't test the bread/dough at all, just the water. Although you may be surprised how often a pH test can be useful - Not sure if the caustic has been fully flushed from the CIP line - check the pH!! Just one example.They are not that expensive either.

A lot of things that can affect water quality can also affect the pH, so if the pH in your steam is the same as the incoming potable water, you can have a higher level of confidence that nothing is affecting it during your steam generation.

Conductivity - most pH meters (the good ones) also have a conductivity function. Again if the conductivity is the same steam vs incoming water, then again extra confidence that the steam is not being "dirtied" by anything, rusting pipes, sludge build up etc, as conductivity is a good quick guide to water purity. Same with a visual and taste aroma comparison.

So no large pH variances, no large conductivity variance, water clarity is the same, all adds up to being confident that the steam is okay. The only difficulty we faced was initially how to get a sample of the steam, we were a cannery so we were running high temp and high pressure steam lines.

NB the variances in pH and conductivity you will get to understand/know once you have some historical data. Test your incoming water daily for a few weeks, you will good data re "normal variance".

Bawdy.

[Charles.C]

Thanks for your help. It's one of those bizarre things that I'm not sure pH would make a jot of difference to our product anyway and I'd be testing it for the sake of testing!!! Still a pH probe might be an idea. How do you test conductivity? It's been a while since I was a chemist!

Btw, for info, we make bread.

For many external food suppliers to EC, the answer to "supply what data" is automatically/semi-legislatively replied via a "sampling" of the official EC "water" requirements (an enormous BCP list) but which typically results in doing something like "B" = (apc/coliform/E.coli generic plus 2-3 esoteric others,, "C" = heavy metal group plus 4-5 typical other inorganic metals, "P" = approx 6-9 items like pH, conductivity, smell, taste, etc. Not exactly a cheap compilation and very nice business for the lab. IMEX (not to forget the included dummy sample to keep things in balance ).

The limits for all the above items plus, maybe, a hundred more (eg organic contaminants) are also given in the EC directive. (Analogous to WHO etc).

Of course, as you suggest, one would hv thought that an official "negative release" from the Metropolitan supply would hv sufficed, but in practice, IMEX, NO NO.

Steam is a new one on me also ! Consult the boiler supplier perhaps ?

Rgds / Charles.C

[GMO]

I'd love to see how any of the sludge, metal contaminants etc, etc is meant to make it into the product via steam anyway.

This is like the temperature monitoring (for our site). We are required to move to 4 hourly or continuous temperature monitoring of our chiller because it says so in the BRC standard. Does it have any bearing on the safety of the product? No. We keep butter, cheddar and yeast in the chiller, all of which are perfectly safe at 10 degrees let alone 5 and all of which will be baked prior to consumption.

Ridiculous! I always rated BRC but now I miss the "risk assessment" approach of version 5. I could perfectly happily cover all of this off with risk assessment!!!

[Foodworker]

Bawdy touches upon a test on water which is rarely carried out, and that is a visual and organoleptic examination.

A chemical analysis will normally only tell you the result for that test, and only that test, and may not uncover an additional problem. It is also done against a schedule of frequency often based on cost rather than need.

If you look at a water sample against a white background and then a black background you can often see discolourations and turbidity quite easily. This may not tell you the cause of the problem, but will allow you to investigate further.

The advantage of this is that it is simple to do regularly and it is free.

Organoleptic tests again can be easily done on site, just be sure of the source before you taste it.

On its own this would not satisfy the BRC clause but it does give more confidence to your usage of water

[GMO]

Bawdy touches upon a test on water which is rarely carried out, and that is a visual and organoleptic examination.

A chemical analysis will normally only tell you the result for that test, and only that test, and may not uncover an additional problem. It is also done against a schedule of frequency often based on cost rather than need.

If you look at a water sample against a white background and then a black background you can often see discolourations and turbidity quite easily. This may not tell you the cause of the problem, but will allow you to investigate further.

The advantage of this is that it is simple to do regularly and it is free.

Organoleptic tests again can be easily done on site, just be sure of the source before you taste it.

On its own this would not satisfy the BRC clause but it does give more confidence to your usage of water

Thank you! That's a really good idea. It might also ensure I have a basis to only test annually for chemical contaminants if, say, we're testing monthly for organoleptic. We could easily combine this with sample taking for micro (just taking an additional sample).

[Tony-C]

BRC Issue 6 does require analysis based on risk:

Clause 4.5.1
The sampling points and frequency of analysis shall be based on risk

This is based on source, supply history, water distribution system and usage.

If using water daily then I would test daily:
Micro - TVC/Entero
Chem - Residual Chlorine/Turbidity/Conductivity/pH/Taste

More detailed testing done periodically based on history and risk.

WHO Guidelines here

Useful information on potential contaminants here

Steam can be sampled from condensate traps.

Regards,

Tony

[trubertq]

Cripes!
We just used the annual chemical testing done by water supplier, because as you say the list would be endless, and we cehck different hose outlets within the factory every 3 months for microbiology. Oh and we check the chlorine levels twice a day cos we super chlorinate...
As for checking steam.... tell them to try to check the steam in a retort!! ( such are the vagaries of a one size fits all standard, I would argue my case about the steam... I really would).

Can you speak to your water supplier and explain the situation to them, that you need results annually??

[GMO]

Can you speak to your water supplier and explain the situation to them, that you need results annually??

It took two months of nagging for them to put up the 2010 results! In about September all that was up was 2009! Only the 9 months to fill in a table then...

[trubertq]

It took two months of nagging for them to put up the 2010 results! In about September all that was up was 2009! Only the 9 months to fill in a table then...

Oops sorry for stating the bloody obvious

[mind over matter]

Issue 6, section 4.5.1; The microbiological and chemical quality of water shall be analysed at least annually.

Do you test your water chemically as well as microbiologically? Is the water supplier's testing for chemical contaminants sufficient? (They refuse to publish results in my area until the full calendar year has passed and then they take 6 months to publish the summary, so, in March 2012, i will be able to tell my auditor the chemical safety was fine throughout 2010... Helpful. )

Section 4.5.4; Air, other gases and steam used directly in contact with or as an ingredient in products shall be monitored to ensure this does not represent a contamination risk.

How do you monitor steam? Any ideas?

Is there any local requirement for the frequency of water analysis in your state/country? Based on risk assessment, what's your business requirement?

[GMO]

Is there any local requirement for the frequency of water analysis in your state/country? Based on risk assessment, what's your business requirement?

Our business requirement is to pass BRC. BRC v6 requires minimum annual chemical water testing.

[Foodworker]

There is a danger that you may becoming too concerned about something that you do not need to be..

A water company has a legal obligation to provide potable water, safe to consume. (Apologies, this is a UK based post) They have greater resources and knowledge to do this than most food companies.

Sampling plans as far as I understand it are based upon the Ordnance Survey grid and an any published results relate to an area within a 1 sq.km zone.

Requesting the test results, whilst quite interesting, will actually serve no real purpose as they will almost certainly be historic and not relate directly to the water that you use. It is your right to expect that the water will meet legal standards.

My understanding is that water companies have an obligation to report incidents when the water fails to meet legal standards. Perhaps you can request from them a statement detailing any instances of non compliance rather than a full analytical report. It is possible that they are obliged to post this information anyway

As soon as their water enters your pipework, you can change any properties, and any of their results are void.

Having a plan of your own water distribution is the first step to setting up your own sampling and testing system. The sampling points, type of analysis and frequency is where you should apply a risk assessment, taking into account the source (eg is there a header tank), how the water is used and your type of product.

Edited by Foodworker, 06 December 2011 - 08:04 PM.

[Jim E.]

Water testing here is completed on a monthly basis since we take water from the city water supply. We test for Total coliforms and E. coli. Then on a yearly basis we send out water samples for a full blown enviromental test. We also check chlorine levels of incoming water 4 times a day.

As for steam we use it as a process step (steam peel potatoes). We must test our boiler water for numerous items but these are to ensure that boiler chemicals we use are not carried over in excess to the steam used in the plant. As stated above we check for conductivity, pH, hardness and alkalinity. These test procedures are all supplied by our boiler chemical supplier.

Hope this helps.

Edited by Jim E., 09 December 2011 - 04:06 PM.

[alexsull]

Having a plan of your own water distribution is the first step to setting up your own sampling and testing system. The sampling points, type of analysis and frequency is where you should apply a risk assessment, taking into account the source (eg is there a header tank), how the water is used and your type of product.

BRC 6 refers specifically to a water distribution plan. We have had lengthy conversations on what a "water distribution plan" is ranging from a block diagram showing major components all the way to a detailed CAD drawing of our water distribution system including pipe type, size, flow rates, etc.

I am interested in how others are preparing their "water distribution plans". Please share your practices.
Best regards
Alex

[GMO]

BRC 6 refers specifically to a water distribution plan. We have had lengthy conversations on what a "water distribution plan" is ranging from a block diagram showing major components all the way to a detailed CAD drawing of our water distribution system including pipe type, size, flow rates, etc.

I am interested in how others are preparing their "water distribution plans". Please share your practices.
Best regards
Alex

If you have a CAD drawing; great but check it's accurate. IME, cad drawings for water supply are drawn up prior to installation and then the plumber finds there's something in the way and the sink gets moved etc.

I didn't have the luxury of a CAD drawing at my current site, however, I am lucky enough that the water pipes are not hidden behind walls so I basically walked around with the plumber who installed a lot of the water system and put it on a factory plan. Nothing fancy, just a plan I've drawn out on Word. TBH if that's not acceptable, I would think they were being a bit blooming picky.

[mgourley]

If you have a CAD drawing; great but check it's accurate. IME, cad drawings for water supply are drawn up prior to installation and then the plumber finds there's something in the way and the sink gets moved etc.

I didn't have the luxury of a CAD drawing at my current site, however, I am lucky enough that the water pipes are not hidden behind walls so I basically walked around with the plumber who installed a lot of the water system and put it on a factory plan. Nothing fancy, just a plan I've drawn out on Word. TBH if that's not acceptable, I would think they were being a bit blooming picky.

It would be most helpful if BRC would release an interpretation guide when they release a new standard. I'm not sure why this is so difficult. They approved the standard, one would assume they know what needs to be done to meet the intent of the standard.

[Simon]

It would be most helpful if BRC would release an interpretation guide when they release a new standard. I'm not sure why this is so difficult. They approved the standard, one would assume they know what needs to be done to meet the intent of the standard.

I don't want to sound like a cynic, but maybe its because interpretation guides are free and BRC Standards are £90 each, so not a top priority to get them published.

Regards,
Simon

[mgourley]

I don't want to sound like a cynic, but maybe its because interpretation guides are free and BRC Standards are £90 each, so not a top priority to get them published.

Regards,
Simon

IIRC, they charge for the interpretation guides as well.

[Tony-C]

Yep £42 + VAT for pdf & £45 + VAT for hard copy

http://www.tsoshop.c...35946&DI=633637

[GMO]

So the standard is deliberately vague to ensure you also buy the interpretation guide! I suspect the useful sections of the FAQs may disappear off the website once it is too!

Well I do have an answer to my questions and after some particularly dogged questioning. It took me over 1 month to get a full answer to both of these from the BRC.

For water this is what I was told:

With 4.5.1 - The type of chemical checks should be based on a risk assessment. For instance if as in the UK the water is supplied by a water authority an analysis from the authority would suffice unless there are other risks identified in the delivery system e.g. Lead pipes. Where water is extracted from bore holes and or sites have on site treatment facilities then additional checks will be required to ensure the water is not contaminated either at the bore hole or in treatment. So we would suggest that as long as you have the most recently available tests from your water board and you do not have any other risks then this will be okay.

For steam this is what I was initially told:

4.5 – We would suggest that the steam is used as part of the cooking process and could therefore be covered by the Standard. The main issue with this is not from a pathogen perspective but due to the act that boilers use chemicals to prevent corrosion and so you would need to ensure that the steam is assessed to ensure that these chemicals are not carried over and contaminate the product. These tests should be able to be done in conjunction with your boiler engineers who can take a sample of the steam, condense and then analyse it.

Then I found out the type of boilers we have don't have any anti corrosion chemicals added (because they don't need them) so I pushed again, I was initially told we still needed to test,

With regard to the steam testing, we would recommend that it is analysed once to ensure that you have evidence there are no chemicals etc. that could cause a food safety risk and once this has been done then you would monitor periodically just to ensure that no new risks have been introduced at any point.

However, when I said "well what for?" they eventually came back with this:

The main concern with regard to steam is the carry over of additives introduced into the boiler water which may contaminate products. It is usual to add water softeners, anti corrosion agents to the boiler we understand to protect and increase the life of the boiler. If these are not used or indeed are used but not for the water used to generate the steam for food contact then this is not an issue.

Clearly the steam generated will be microbiologically sterile. So as long as potable water is being used to generate the steam and there are no additional risks added by holding tanks, lead pipes etc then the usual checks on water quality (or certificate from the water board) should suffice.

I think I wore them down

Edited by GMO, 09 February 2012 - 07:06 AM.