17 replies to this topic

[AZuzack]

I've been at Food Chemical and Meat manufacturing companies for 14 years.  I have never seen water on a flow chart for HACCP.  I live in an area with really good municipal water where no one really thinks about it.  My plant does not treat the water that comes in.  It is used to make a solution of ingredients and added.  I wasn't here for the pre-audit assessment, but the report says "Water, as an input, was not identified" on the HACCP plan flow diagrams.  So for BRC, does City water need it's own little box on the flow chart? Is it multiple boxes/steps?  Does a water heater count as a storage tank?  

[KellyQA]

Yes, water should have its own box on the flow and then an arrow to where it goes into your process. On the hazard analysis, water should also be addressed. My facility uses city water that goes into ice machines to make ice, used as an ingredient, and also used as steam. 

 

City water -> ingredient scaling. 

City water -> ice machine -> Ice > ingredient scaling

City water -> steam -> process step.

 

Hazards typically associated with water are: E coli, Coliforms, APC, drug residues, heavy metals, unapproved additives

Water should meet all local and national water requirements. 

 

 

Make sure to obtain  a water quality report from your city every year. Do you send out water samples to be tested at least annually for e.coli/coliforms and HPC?

 

Does the water heater actually hold water on site? 

[GMO]

Yep water should be on there.  It's sometimes an ingredient and if it is, absolutely on the flow diagram.  If only for cleaning then yes I would include somewhere in a prerequisite programme but documented in your HACCP and hazard analysis as a generic control.  In the UK as well we would always contact the authority to get them to inform us if there were boil water notices (rare but occasionally happens).  It also then encourages you to look into water storage across your plant and how that's controlled.  Lastly in some applications, e.g. beverage, even the good potable water standards in the UK are insufficient so will need further on site treatment.

 

So it is something which can carry hazards so it should be on there.  Your auditor was right.

Edited by GMO, 22 February 2025 - 06:20 AM.

[Scampi]

Yes, water should be on there, the flow chart AND the hazard analysis

 

I test municipal water in the plant twice/year for potability and once/year for heavy metals. I also include the local water report from the municipality

 

 

This is to ensure there isn't anything occurring between the water treatment plant and my food contact surfaces

[AZuzack]

Yes, water should have its own box on the flow and then an arrow to where it goes into your process. On the hazard analysis, water should also be addressed. My facility uses city water that goes into ice machines to make ice, used as an ingredient, and also used as steam. 

 

City water -> ingredient scaling. 

City water -> ice machine -> Ice > ingredient scaling

City water -> steam -> process step.

 

Hazards typically associated with water are: E coli, Coliforms, APC, drug residues, heavy metals, unapproved additives

Water should meet all local and national water requirements. 

 

 

Make sure to obtain  a water quality report from your city every year. Do you send out water samples to be tested at least annually for e.coli/coliforms and HPC?

 

Does the water heater actually hold water on site? 

We have water quality reports and if we didn't I at least know how to get them. I'm not sure if my new company tests water.  I'm only two weeks into this company so there's a lot of jumbled conversations in my head.  One previous job tested water after the back flow preventer (the spot where the plant owned the water), but all of their food chemical products boiled off the water and the end products were tested for EU, FCC, and USP compliance.  The other company had SQF certification and tested water at various points of use but I do not remember it being on the HACCP plans.  That end product was cooked on site which mitigated microbial concerns within the product from the water.  There was a blanket statement of nonmeat ingredients so in some ways that covers it but in the associated risks it would need to be called out separately.  I'm kinda using the forum as a device just to help sort through all the stuff in my brain.  And sometimes I get hung up on the regs being stupid and I struggle to submit to the idiocracy.  I really appreciate everyone chiming in.  Looks like I'm adding another box and arrows to my flow chart and asking for the water flow plans so I can understand where the water heater is and what comes after it.  

Thanks Everyone.

[veruca]

Water included and mapped as KellyQA showed in their example. Local water report on file and we do monthly testing from mutliple inlet sources in the plant to check internal plumbing isn't causing potential issues. Even if water is only being used for wash down/ hand washing, it was still suggested heavily to keep it on the HACCP.

[G M]

There are ingredient addition points, and if water is one of the inputs it can be included there.  I do not want a 200 page long flow chart, so I do not call out each ingredient individually.  The only exceptions are a couple of ingredients with specific added regulatory requirements related to risks, which are also addressed individually in other documents.

[Ahead]

In our facility, we utilize water to shower our products after they have been cooked in our Smokehouse, which is post-lethality. We currently perform weekly water tests for E. coli/coliform and send water samples to an external lab bi-annually. However, we have never tested water specifically for Lm,  Should we?

[GMO]

In our facility, we utilize water to shower our products after they have been cooked in our Smokehouse, which is post-lethality. We currently perform weekly water tests for E. coli/coliform and send water samples to an external lab bi-annually. However, we have never tested water specifically for Lm,  Should we?

 

Personally I don't think so.  Coliforms, E Coli and I'd also check for any unusual TVC changes (the normal water testing suites in the UK do so at two different temperatures) which are for trending / indicators.  I have picked up issues on TVC before which were around poor tap hygiene which we then addressed so it was worth doing.

 

BUT what I would do is test that environment extensively in that area as if there is water splashing off surfaces and it's routinely wet in there I bet you Listeria is present routinely and possibly then being splashed onto the product.  Not from the water but because it's so wet.  Do you have to shower it with water?  Is that for a good reason?

[AZuzack]

I assume, based on my experience, you are showering to bring the temperature down quickly, improve peel of the casing and maybe remove smoke residue. And I am also assuming that you are using a semi-permeable casing for a sausage product or a meat "log" that then gets further processed.  

 

I would include the shower nozzles as part of the environmental listeria swabs or sanitation ATP swabs but not an everyday thing considering you're smoking to high temps and should be killing things on the nozzles and potentially cleaning smokehouses to get rid of the smoke residue between products.  If you start getting positives from those things, then you consider testing the water itself as part of the investigation.  

 

Why are you testing the water weekly?  Without a history of positive results, that seems like overkill, but I live where the city water is really clean.  

[Ahead]

Personally I don't think so.  Coliforms, E Coli and I'd also check for any unusual TVC changes (the normal water testing suites in the UK do so at two different temperatures) which are for trending / indicators.  I have picked up issues on TVC before which were around poor tap hygiene which we then addressed so it was worth doing.

 

BUT what I would do is test that environment extensively in that area as if there is water splashing off surfaces and it's routinely wet in there I bet you Listeria is present routinely and possibly then being splashed onto the product.  Not from the water but because it's so wet.  Do you have to shower it with water?  Is that for a good reason?

We use water showering primarily to cool down the product and assist with casing removal. 

[Ahead]

 

I assume, based on my experience, you are showering to bring the temperature down quickly, improve peel of the casing and maybe remove smoke residue. And I am also assuming that you are using a semi-permeable casing for a sausage product or a meat "log" that then gets further processed.  

 

I would include the shower nozzles as part of the environmental listeria swabs or sanitation ATP swabs but not an everyday thing considering you're smoking to high temps and should be killing things on the nozzles and potentially cleaning smokehouses to get rid of the smoke residue between products.  If you start getting positives from those things, then you consider testing the water itself as part of the investigation.  

 

Why are you testing the water weekly?  Without a history of positive results, that seems like overkill, but I live where the city water is really clean.  

 

 

You are correct on both points. Our post-cooking shower process serves the purposes of temperature reduction, casing peel improvement.

 

Regarding sanitation, we remove the rinse lines monthly as part of our Master Sanitation Schedule (MSS) and submerge them in a chemical bath for deep cleaning. Additionally, nozzles are replaced every three months to maintain optimal hygiene and performance.

That’s a great suggestion—I will look into adding the shower nozzles to our Random Site Generator for weekly ATP swabbing as part of our sanitation program.

We conduct weekly water testing as a preventive measure, rather than in response to historical positives. This policy was already in place before I assumed my role with the company. Up to this point, we have not specifically tested post-cook shower water for Listeria monocytogenes (Lm), as there has been no identified risk in our hazard analysis.

However, during a recent discussion with our USDA inspector, it was brought to our attention in preparation for our upcoming Food Safety Assessment (FSA).  that the Notice of Intended Enforcement (NOIE) review will request whether post-cook water is addressed in our HACCP flow chart and whether we have a history of Lm testing in post-lethality water at the smokehouse.

Given this, we are currently reviewing our hazard analysis and preventive controls to determine the appropriate approach to ensure compliance.

[AZuzack]

You are correct on both points. Our post-cooking shower process serves the purposes of temperature reduction, casing peel improvement.

 

Regarding sanitation, we remove the rinse lines monthly as part of our Master Sanitation Schedule (MSS) and submerge them in a chemical bath for deep cleaning. Additionally, nozzles are replaced every three months to maintain optimal hygiene and performance.

That’s a great suggestion—I will look into adding the shower nozzles to our Random Site Generator for weekly ATP swabbing as part of our sanitation program.

We conduct weekly water testing as a preventive measure, rather than in response to historical positives. This policy was already in place before I assumed my role with the company. Up to this point, we have not specifically tested post-cook shower water for Listeria monocytogenes (Lm), as there has been no identified risk in our hazard analysis.

However, during a recent discussion with our USDA inspector, it was brought to our attention in preparation for our upcoming Food Safety Assessment (FSA).  that the Notice of Intended Enforcement (NOIE) review will request whether post-cook water is addressed in our HACCP flow chart and whether we have a history of Lm testing in post-lethality water at the smokehouse.

Given this, we are currently reviewing our hazard analysis and preventive controls to determine the appropriate approach to ensure compliance.

Is your product post lethality exposed ready to eat (PLE RTE)?  I just switched jobs and my previous employer had 2 smokehouses but no post lethality exposed product.  That USDA inspector did not mention this while I was there.  I know the USDA is really scrambling to mitigate Listeria contamination in PLE RTE foods (Thanks Boars Head!)

 

If they want it addressed by testing then you could start with a weekly test, after 5-9 weeks of negatives switch to monthly, after 7-13 months switch to bi-annual.  If you get any positives, you may have to stay at a more frequent testing plan, but if you don't get any positives then you have just justified less frequent testing. 

[Ahead]

Is your product post lethality exposed ready to eat (PLE RTE)?  I just switched jobs and my previous employer had 2 smokehouses but no post lethality exposed product.  That USDA inspector did not mention this while I was there.  I know the USDA is really scrambling to mitigate Listeria contamination in PLE RTE foods (Thanks Boars Head!)

 

If they want it addressed by testing then you could start with a weekly test, after 5-9 weeks of negatives switch to monthly, after 7-13 months switch to bi-annual.  If you get any positives, you may have to stay at a more frequent testing plan, but if you don't get any positives then you have just justified less frequent testing. 

Yes, we are PLE RTE and from what I have heard this is from the BrucePac listeria outbreak     

[AZuzack]

Yes, we are PLE RTE and from what I have heard this is from the BrucePac listeria outbreak     

Yes, that was the other one last fall that was a big deal. 

[AZuzack]

Finally found an example and it is just water in its own box.  

 

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[GMO]

I think I understand the process more now from what people have been replying with.

 

Yes it definitely sounds like that water will bring risk and not just from the water itself but the wet environment being created in the room.   I don't honestly think you'll ever find Listeria in the water unless your water system is terrible but it's not a bad thing to test as due diligence.  It's better to test the water as a product sample than to try to swab a very wet area as all that can do is wash off the nutrient medium and give you a false negative.

 

That said, the wet environment of where you're doing that activity is absolutely prime for Listeria survival and growth.  So hygiene of that total area is key. 

 

I don't know what happened in the Boars Head case (has that been released yet?)  But I was supplied by a manufacturer producing ham bombs.  Just hams cooked in plastic, not smoked.  We had loads of problems with Coliforms.  We found out that post cook (in the plastic) they were then opening the plastic and draining them.  We'd not asked them to do this and we were happy to do it ourselves.  Also it created other risks at least in theory with C. bot. but that's another issue.  We stopped them from draining the hams and guess what?  The micro issues disappeared.  

 

What had to have been happening was post cook recontamination of the hams as inside the bags they were close to sterile.  I very much doubt it was anything to do with cooling (but yes that has been issues in the past in some plants but mostly around more air moving apparatus) but much more to do with hands and the vacuum packer they were using.  The point of my slightly long winded story is that test the water as it comes out of your nozzles all you like but there are other risks in that area created by the water which I'd put money on being more significant.

[Ahead]

Finally found an example and it is just water in its own box.  

Is this from your facilities plan? If not, can you direct me to where you found this?