EU and USFDA standards for residual disinfectant levels
Hi all
During a recent audit we got pulled up for not doing chlorine residue tests on our water. For reference this relates to BAP SPS 5.1 Section 3.13.2.
My query is where do I find the required levels in the EU and USFDA and also how is the best way to go about testing for this on a daily basis?
I am located in Australia and we only use town water in our factory which is highly regulated already. Is there a way to use the local water company's regulations and monitoring to do a risk assessment to avoid having to put these tests in place?
Any advice would be greatly appreciated.
Standard ref - Water used in food production areas shall be assured safe and in compliance with USDFA and/or EU standards for microbial and chemical contaminants and disinfection treatments. Routine water quality checks during production days shall be carried out by the facility for residual disinfectant levels (such as chlorine or ozone). These checks shall occur at a minimum daily. The facility shall also test as for the presence of coliforms at minimum every 2 weeks.
Non-Conformance - Coliform check on water were conducted every 2 weeks, latest Jan 18 & Feb 7, 2024 by BVAQ Lab, result compliant but frequency more than 2 weeks, not compliant to every 2 weeks and Chlorine residue was not monitor daily in production. .
For the EU, the relevant reference is likely to be Directive 2020/2184, the so-called Drinking Water Directive: https://eur-lex.euro...ir/2020/2184/oj
Possibly also worth noting that some chlorine residues are also covered by pesticide and contaminants regulations in the EU, which may require consideration for some applications - these limits apply to the foodstuff rather than the water you're using, but if there is the potential for significant water inclusion or carryover then you will likely need to consider this if you're exporting to the EU market.
Chlorates are covered as a pesticide residue under Regulation (EU) 2020/749. Note that if the maximum residue level for chlorate is exceeded then the onus is on you as a food business to demonstrate that this is from non-pesticide sources - see Footnote A in the regulation: https://eur-lex.euro...reg/2020/749/oj
Perchlorate has a maximum level set in Regulation (EU) 2023/915: https://eur-lex.euro...ELEX:32023R0915
Are you treating the water yourself? If not, then I'd rely on your supplier to test and control chlorine levels rather than you?
The disinfectant levels (i.e. chlorine) would be controlled by your water supplier, and they would be checking this on a daily basis. The level of chlorine would be what's required by Aussie regulations, which I think are based on international requirements. There will/should always be low levels of chlorine in your potable water supply.
Do you do any inhouse sanitisation using hypochlorite in water? If so that would definitely need to be checked to ensure no excessive residual chlorine is present.
It's worth doing your own tests to confirm levels of chlorine are adequate when it reaches your facility. It's simple to test, using a colorimeter or tests strips, and I would rotate the test points across the water outlets around your facility. A quick web search shows many options available for chlorine testing.
Do you have an in house lab, (with micro) as you could also do a simple coliform test using Petrifilm coliform plates. However preference for water testing for coliforms is to test 100 ml by filtration.