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Water Testing - Two conflicting BRC Auditor Views Clause 4.5.1

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BGAQA

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Posted 07 March 2023 - 12:40 AM

"The microbiological and chemical quality of the water shall be analyzed as required by legislation or at least annually..."

 

In our process we do not use water except for hand-washing.

 

All of our water is received from the local government water department which sends us a report annually on the microbiological and chemical testing performed.

 

One BRC auditor says that we must independently test the water ourselves. On the basis of this advice we've been testing it annually.

 

A second BRC auditor says that we can rely on the report provided by the local government.

 

What are your experiences?

 

____

 

In the last audit they mentioned that they had not recognized that we should also be doing chemical analysis.  So if we do continue with testing independently does anyone have any tips on what chemical testing would be suitable? I've read the SOP from the federal government but it is vague.



Charles.C

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Posted 07 March 2023 - 04:07 AM

"The microbiological and chemical quality of the water shall be analyzed as required by legislation or at least annually..."

 

In our process we do not use water except for hand-washing.

 

All of our water is received from the local government water department which sends us a report annually on the microbiological and chemical testing performed.

 

One BRC auditor says that we must independently test the water ourselves. On the basis of this advice we've been testing it annually.

 

A second BRC auditor says that we can rely on the report provided by the local government.

 

What are your experiences?

 

____

 

In the last audit they mentioned that they had not recognized that we should also be doing chemical analysis.  So if we do continue with testing independently does anyone have any tips on what chemical testing would be suitable? I've read the SOP from the federal government but it is vague.

Hi BGAQA,

 

The snag may be that the Gov. report  may not be sampled at point of use. ?

 

No idea about Australia but "potable water" is usually one of the few items whose Local chemical requirements are clearly spelled out (somewhere).

 

From BRC8 Guidelines -

 

The water is expected to comply with national legislation (e.g. EU directive 98/83/EC and its subsequent amendments) or, in the absence of this, with World Health Organization (WHO) standards for drinking water.

Kind Regards,

 

Charles.C


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Tony-C

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Posted 07 March 2023 - 04:57 AM

Hi BGAQA,

 

BRCGS Global Standard for Food Safety Issue 9 requirements for clause 4.5.1 include:

The sampling points, scope of the test and frequency of analysis shall be based on risk, taking into account the source of the water, on-site storage and distribution facilities, previous sample history and usage.

 

The risk isn’t likely to be particularly high if you only use water for hand washing unless your product is handled but the water quality may have deteriorated through storage and distribution on site. For this reason, as Charles has posted I would be sampling at point of use at a minimum annually and more frequently if there is some risk.

 

Basic chemical testing of water usually includes pH, Chlorine, B.O.D. Water Hardness. I would be relying on the local government water analysis for technical chemical analysis.

 

Kind regards,

 

Tony



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SHQuality

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Posted 07 March 2023 - 06:54 AM

The testing performed by the local government and water distribution services test on location at the water treatment plant.

You should be testing your water onsite in the factory.

 

It wouldn't be the first time rusted pipes and damage affect the quality of the water in a factory.

And I doubt you use water only for handwashing.

Do you really mean to say you never do any wet cleaning of surfaces and machines?


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Rose Karuma

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Posted 07 March 2023 - 07:17 AM

Hi team,

 

I think EU directive 98/83 EC became invalid from 12/01/2023 and the one in force now is EU Directive 2020/2184 on the quality of water intended for human consumption.

I stand corrected.

 

regards

Rose k

Hi BGAQA,

 

The snag may be that the Gov. report  may not be sampled at point of use. ?

 

No idea about Australia but "potable water" is usually one of the few items whose Local chemical requirements are clearly spelled out (somewhere).

 

From BRC8 Guidelines -


Edited by Rose Karuma, 07 March 2023 - 07:18 AM.


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MDaleDDF

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Posted 07 March 2023 - 05:51 PM

I agree with SHQ.   We test annually even though we're provided with testing by the municipality supplier, because we're testing our building after the water reaches us.  



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BGAQA

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Posted 07 March 2023 - 07:53 PM

Since posting and looking at the Interpretation Guide for Issue 9, "If the water is supplied by a water supply company, a chemical analysis from the water company will suffice for the chemical requirements unless there are other risks identified in the delivery system (e.g. lead pipes)."

 

But I'd still have to test for micro, which is what we've been doing.



Charles.C

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Posted 08 March 2023 - 03:05 AM

Since posting and looking at the Interpretation Guide for Issue 9, "If the water is supplied by a water supply company, a chemical analysis from the water company will suffice for the chemical requirements unless there are other risks identified in the delivery system (e.g. lead pipes)."

 

But I'd still have to test for micro, which is what we've been doing.

Hi BGAQA,

 

Note that the quoted text is for "Guidance." The Standard's text is the Primary requirement albeit this can in practice sometimes  involve, possibly subjective, "Interpretation". One can see the degree of importance BRC (et al)  attach to "Water" -

 

Attached File  BRC9 - Water within Production and Storage Areas.png   151.07KB   5 downloads

 

IMEX for BRC, (export to EC) where Local Legislation is non-specific, a small batch of representative  POU samples annually analysed for a  limited selection of "typical" Physical/Chemical/Microbiological items taken from the  EC Directive's encyclopedic requirement menu, (eg heavy metals, APC, generic E.coli, pH, dissolved solids, etc) can be sufficient for routine purposes in the absence of any significant non-compliances. Routine, minimal, in-house, micro.checks also done. Supplementary, official, reports approving the water supply for use in Food Production are also of assistance.


Kind Regards,

 

Charles.C


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BGAQA

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Posted 08 March 2023 - 03:15 AM

I'm comfortable with the interpretation given our use of water is limited (hand washing, especially since the workers don't touch the ingredient).

 

If we were using it for cleaning or as a part of our processing I would certainly be testing far beyond what the standard calls for.

 

Thanks everyone.



SHQuality

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Posted 08 March 2023 - 07:17 AM

I'm comfortable with the interpretation given our use of water is limited (hand washing, especially since the workers don't touch the ingredient).

 

If we were using it for cleaning or as a part of our processing I would certainly be testing far beyond what the standard calls for.

 

Thanks everyone.

How are you cleaning if you're not using water in your cleaning procedures?

I have come across very few ingredients that can be handled with dry cleaning exclusively.



liberator

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Posted 08 March 2023 - 09:18 PM

Per the Australia New Zealand Food Standards Code - Standard 3.2.3 - Food Premises and Equipment:

4             Water supply
(1)           Food premises must have an adequate supply of water if water is to be used at the food premises for any of the activities conducted on the food premises.
(2)           Subject to subclause (3), a food business must use potable water for all activities that use water that are conducted on the food premises. (This would include hand washing)
(3)           If a food business demonstrates that the use of non-potable water for a purpose will not adversely affect the safety of the food handled by the food business, the food business may use non-potable water for that purpose.
 
 
You can rely on your water supplier to provide you with their micro water analysis data - which should be available online from their web site. 
 
However as the water supplier has no control of the water quality once it leaves their facility and enters your site, how do you know there is not a source of contamination occurring in the water on your site? How do you verify that the water being used meets the requirement for being potable?
 
Do you have taps/washbasins hoses etc that are not used for long periods of time? Dead ended water lines? Only being used for handwashing, are you certain? What about for drinking, what do your operators do there?  There is always the possibility for the water to be used on site by your employees for purposes you are unaware of, assumptions can be a very dangerous thing.
 
I would be randomly testing the water quality ex the potable water outlets over months, testing for coliforms and e.coli per 100ml (A requirement for dairy in Aust.)
 
Collect some data to show there is or is no issue with the water quality, handwashing only or not. Once you have the data you can review the risk and change the frequency of testing. Without this data you're only working to assumptions and are flying blind.


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Charles.C

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Posted 09 March 2023 - 07:37 AM

 

Per the Australia New Zealand Food Standards Code - Standard 3.2.3 - Food Premises and Equipment:

4             Water supply
(1)           Food premises must have an adequate supply of water if water is to be used at the food premises for any of the activities conducted on the food premises.
(2)           Subject to subclause (3), a food business must use potable water for all activities that use water that are conducted on the food premises. (This would include hand washing)
(3)           If a food business demonstrates that the use of non-potable water for a purpose will not adversely affect the safety of the food handled by the food business, the food business may use non-potable water for that purpose.
 
 
You can rely on your water supplier to provide you with their micro water analysis data - which should be available online from their web site. 
 
However as the water supplier has no control of the water quality once it leaves their facility and enters your site, how do you know there is not a source of contamination occurring in the water on your site? How do you verify that the water being used meets the requirement for being potable?
 
Do you have taps/washbasins hoses etc that are not used for long periods of time? Dead ended water lines? Only being used for handwashing, are you certain? What about for drinking, what do your operators do there?  There is always the possibility for the water to be used on site by your employees for purposes you are unaware of, assumptions can be a very dangerous thing.
 
I would be randomly testing the water quality ex the potable water outlets over months, testing for coliforms and e.coli per 100ml (A requirement for dairy in Aust.)
 
Collect some data to show there is or is no issue with the water quality, handwashing only or not. Once you have the data you can review the risk and change the frequency of testing. Without this data you're only working to assumptions and are flying blind.

 

Hi Liberator,

 

Thks for input but where is ANZFA's quantification of so-called "potable water" ?


Kind Regards,

 

Charles.C


Aliali

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Posted 12 March 2023 - 03:58 AM

Our local registered supplier provides us test results quarterly and we test water once a year.



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Posted 13 March 2023 - 07:08 AM

Good day

 

if you read the next clause, 4.5.2, it talks about the need to have the water distribution map and sampling points being based on that map, in your case your sampling points being the hand washing stations. the basis for this is your water distribution itself could be contaminated thus sampling being done at points of use.



tauraichiduza

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Posted 13 March 2023 - 07:10 AM

The other issue could be credibility of the testing lab, see also clause 5.6 of the BRCGS standard



liberator

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Posted 14 March 2023 - 02:10 AM

Hi Liberator,

 

Thks for input but where is ANZFA's quantification of so-called "potable water" ?

Hi Charles,

 

the FSANZ for potable water uses the Australian Drinking Water Guidelines to define potable water and its requirements.

 

https://www.nhmrc.go...blications/eh52



hello.fizz

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Posted 14 March 2023 - 03:17 AM

We have been told that we needed to test it as the test was to see if our pipes were contaminated. We just did an e. coli test each year for the hand wash tap and that was sufficient (SQF).



SHQuality

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Posted 14 March 2023 - 03:15 PM

We have been told that we needed to test it as the test was to see if our pipes were contaminated. We just did an e. coli test each year for the hand wash tap and that was sufficient (SQF).

Do you know what your pipes are made of?

 

Some of my suppliers also test of color or certain minerals so they can find breakage because of rust or other contaminants before they become a problem.



SerenityNow!

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Posted 14 March 2023 - 09:49 PM

In a past life, we were advised that along with the municipal water report, we are to test at different points at our facility.  This helps determine how the water supply quality throughout the facility.  The results can give you an idea if there are pipe/plumbing issues (i.e. broken, rusted pipes) from one location to the next.  

  • Incoming: Faucet at the front of the building.  The nearest location to the street municipal supply.  Verifies that the incoming is satisfactory.
  • Handwashing locations, ware washing locations. 
  • Furthest from the street municipal incoming supply (Back of our building, outside faucet)

On one occasion, we were told we should test incoming at the street level, in front of our building.  We hired someone who was certified to perform that particular test as we couldn't get to the location.



hello.fizz

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Posted 21 March 2023 - 03:07 AM

Do you know what your pipes are made of?

 

Some of my suppliers also test of color or certain minerals so they can find breakage because of rust or other contaminants before they become a problem.

 

Not sure what the pipes are made of, but the only focus for us is microbial contamination.



SHQuality

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Posted 21 March 2023 - 06:48 AM

Not sure what the pipes are made of, but the only focus for us is microbial contamination.

Well, if a pipe bursts because of rust, the risk of microbial contamination is going up.





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