8 replies to this topic

[imeandmyself]

Hello all,

I need some help with a recurring issue regarding our potable water, which we use in both production and as bottled water. The water has consistently failed the Heterotrophic Colony Count (HTPC) test. While our products are low risk and undergo further cooking by consumers, we are BRC certified.

Initially, the supplier replaced the water bottles, dispensers, and provided a credit when the issue arose. Both of us send samples to the same lab for testing, but their water passes while ours fails. The supplier provided only one Certificate of Analysis (CoA), but it's unclear if it corresponds to the same batch. This problem has persisted since October last year, and we've even shared the consistently passing tap water results. However, the supplier's HTPC count (both at 24°C and 36°C) is almost 10 times the acceptable limit of <500 CFU/ml.

Although the upper limit for HTPC is specified as <500 CFU/ml, there is no formal standard or document providing this number, only guidelines suggesting that numbers should remain "low." This leaves us wondering: How do we determine when the count is too high?

This month, when the water failed again, the supplier claimed HTPC is only an indicator and that they don't need to adhere strictly to the 500 CFU/ml limit. This seems to show minimal effort to maintain their HACCP certification, and I believe their stance on HTPC count is misleading.

We are planning to change suppliers soon, but before we do, I want to inform them that the high HTPC count should be investigated. Does anyone know of any scientific papers, studies, or evidence showing that a high HTPC count (with a specific number) could lead to biofilm formation, potentially masking pathogen detection or creating an environment conducive to pathogen growth?

 

Thanks for your time!

 

 

 

[Scampi]

so you're saying you purchase ALL of your water for the facility in tanker form and bottles for water coolers?

 

Clarify this point so we can assist

[chrisrushworth]

You state there samples are passing.. but are you testing from the same sampling points?

 

Are you doing the sampling at the same time?

Same bottles? Any Sodium thio in the bottles?

Same lab to test? Same operators? Are they performing an aseptic technique (flaming or wiping the bottle neck before pouring out)

 

Have you checked your filters?

Has you pipework been cleaned regularly? 

 

Have you checked at tanker/pall icon, then at different points through the pipework to determine if there is a part causing contamination.

All water systems should be chlorinated at least annually, or as you have stated you start to see an increase in trends. When was the pipe work last cleaned? This included any holding tanks, have you check there is no visible mould growth to walls/lids of containers?

 

Are you filtering as a CCP if its going into product? When were the filters last checked/cleaned?

 

Not sure on the temperatures your testing at.. its normal 22° and 37° from UKAS labs i have worked in and sent samples to now...

 

 

Regard to limits -

 

What is the acceptable CFU ml in drinking water UK?  1000 cfu per ml

Personally/ At my BRCGS sites we have the following limits -

ACC 22° - 10² cfu/ml

ACC 37° - 10²  cfu/ml

Coliforms -  10²  cfu/ml

Enterococci - Not detected

[chrisrushworth]

..

 

Heterotrophic bacteria are able to form biofilms in water processing systems, adhering to pipe materials and colonizing surfaces. The aim of our research was to identify the critical points in the process of bottled water production at which controls can be applied to prevent, reduce, or eliminate water safety hazards. Microbiological monitoring was conducted using the plate count method and luminometry. To identify the bacterial isolates, we used polyphasic identification based on biochemical tests and molecular analysis using ribosomal RNA. The heterotrophic plate counts were higher in the water filtration station, ultrafiltration (UV) disinfection station, and holding tank. At these points of the industrial process, the water is stagnant or there is poor flow. Molecular analysis identified the bacterial isolates as belonging to Acinetobacter, Agrobacterium, Aeromonas, Brevundimonas, Citrobacter, Enterobacter, Klebsiella, Pantoea, and Rhizobium genera. Bacterial isolates showed various levels of biofilm formation, and the best adhesion properties were exhibited by the Aeromonas hydrophila and Citrobacter freundii strains.

[imeandmyself]

Hello all,

 

Apologies.

 

I had been locked out of IFSQN and wasnt able to log in to reply. This is a recurring issue for me for some reason!!

 

Clarifications-

 

-We use commercially bottled water- Each bottle holds 20 litres of water. Its the same type of unit that is normally found in offices for staff use.

 

-The water dispenser is brand new, having been cleaned and flushed before its first use. Both the unit and the water bottle were supplied by the supplier, and the unit is approximately two weeks old. However, the issue existed even with the older dispenser and persisted with the new unit, as we continue to experience high counts.

 

-There are no 'sampling points' as such. We collect water from the tap on the dispenser unit/ watercooler for testing.

 

-We don’t require a large amount of water for processing—around 70-80 liters per week is more than enough. Our factory is located in the middle of a farm, which is why we opted for the best potable water available, as the farm doesn’t have access to the regular city water supply. We use stored water that undergoes filtration and UV treatment. This water is used for handwashing and cleaning of equipments. When tested, this water showed significantly lower HTPC counts compared to commercially bottled water.

 

-The water sample is collected in the bottle provided by the lab for micro testing. It contains sod thio.

 

-I collect the water for testing using highly aseptic methods to ensure accuracy and prevent contamination.

 

-Yes, both of us use the same lab and testing parameters. However, they haven’t openly disclosed the HTPC count, only stating that it passed. They also justified that they are not required to adhere to the 500 CFU/ml limit as its only a guideline. Even if we double the permissible limit, the results still fail, with HTPC counts reaching as high as 4800 CFU/ml.

 

I hope these clarifications provide all the extra information you've requested to help answer my questions.

 

Thanks :)

[chrisrushworth]

 

Hello all,

 

Apologies.

 

I had been locked out of IFSQN and wasnt able to log in to reply. This is a recurring issue for me for some reason!!

 

Clarifications-

 

-We use commercially bottled water- Each bottle holds 20 litres of water. Its the same type of unit that is normally found in offices for staff use.

 

-The water dispenser is brand new, having been cleaned and flushed before its first use. Both the unit and the water bottle were supplied by the supplier, and the unit is approximately two weeks old. However, the issue existed even with the older dispenser and persisted with the new unit, as we continue to experience high counts.

 

-There are no 'sampling points' as such. We collect water from the tap on the dispenser unit/ watercooler for testing.

 

-We don’t require a large amount of water for processing—around 70-80 liters per week is more than enough. Our factory is located in the middle of a farm, which is why we opted for the best potable water available, as the farm doesn’t have access to the regular city water supply. We use stored water that undergoes filtration and UV treatment. This water is used for handwashing and cleaning of equipments. When tested, this water showed significantly lower HTPC counts compared to commercially bottled water.

 

-The water sample is collected in the bottle provided by the lab for micro testing. It contains sod thio.

 

-I collect the water for testing using highly aseptic methods to ensure accuracy and prevent contamination.

 

-Yes, both of us use the same lab and testing parameters. However, they haven’t openly disclosed the HTPC count, only stating that it passed. They also justified that they are not required to adhere to the 500 CFU/ml limit as its only a guideline. Even if we double the permissible limit, the results still fail, with HTPC counts reaching as high as 4800 CFU/ml.

 

I hope these clarifications provide all the extra information you've requested to help answer my questions.

 

Thanks :)

 

 

Why are you concern with the HTPC counts only? What else are you testing for? Do all the other results seems correct? 

Have you performed any trending on the results you are getting?

 

What are your customers expecting you to test for? Is there future processing of your products (Heat treatments?)

Is the product RTE? Are you classed as  HC/HR or LR?

 

 

You state small qty of only 70-80L per week, are the filters being cleaned when changing bottles? 

 

Where are the bottles being stored? How long from delivery to use? Temperature controlled? Are the seals fully intact?

 

You have been back to the manufacturer and ask for there retained samples to be tested? and the results shared with you?

Have you raised NC's/complaints to the manufacturer are asked for investigation?

Have you done a site audit to check what they say they are doing they are actually doing with documented evidence?

You have paid for the lab to test, thus they should provide quantifiable results...

 

You have stated UV & filtration, have you tested the water prior to these CCP steps? To determine that your UV and filters are working correctly?

What stage of production are the UV/filters...

 

...

I would start at the beginning of the process, test on delivery, test when put into dispenser, test after UV, test after filters, test after process, and then test FP's...

   

Edited by chrisrushworth, 13 March 2025 - 11:30 AM.

[imeandmyself]

Thanks for replying, CHRISRUSHWORTH :)

 

We do test for other bacteria- Coliforms, Ecoli and they are Not detected. Its just the HTPC which is an issue.

 

Like I said, its a brand new dispenser and there is no need to change the filters yet.

 

yes, the product is further cooked at consumer level.. it is just flour and water that is mixed and the dough is dried  . we are low care/ low risk.

 

Our factory is one of the cleanest and high standards of hygiene are maintained. The water bottles are stored in a cool and dry and clean place in the 'kitchen'. we use the water bottles and get fresh delivery every 2 weeks. The shelf life is 1 year from the DOM.

 

No, this bottled water doesnt go through any UV. This is commercially bottled ready to drink water. it doesnt undergo any more filteration/ treatments.

I was referring to tank water which we use for cleaning and handwashing only that goes through filteration and UV treatment before being used for cleaning.

 

we dont intend to do site audit anymore as we have decided to change the supplier.

 

My only question was is there any literature/ journal that gives a specific number for HTPC counts in drinking water.

 

Thanks :)

[Scampi]

we had to replace a water cooler after it failed repeated, same water as the others, but I'm assuming there was a small crack in one of the hoses as there wasn't anything obvious to cause the issue.........every other sampling location had great results, and we are on municipal water

 

might be the same for you

[chrisrushworth]

Thanks for replying, CHRISRUSHWORTH :)

 

We do test for other bacteria- Coliforms, Ecoli and they are Not detected. Its just the HTPC which is an issue.

 

Like I said, its a brand new dispenser and there is no need to change the filters yet.

 

yes, the product is further cooked at consumer level.. it is just flour and water that is mixed and the dough is dried  . we are low care/ low risk.

 

Our factory is one of the cleanest and high standards of hygiene are maintained. The water bottles are stored in a cool and dry and clean place in the 'kitchen'. we use the water bottles and get fresh delivery every 2 weeks. The shelf life is 1 year from the DOM.

 

No, this bottled water doesnt go through any UV. This is commercially bottled ready to drink water. it doesnt undergo any more filteration/ treatments.

I was referring to tank water which we use for cleaning and handwashing only that goes through filteration and UV treatment before being used for cleaning.

 

we dont intend to do site audit anymore as we have decided to change the supplier.

 

My only question was is there any literature/ journal that gives a specific number for HTPC counts in drinking water.

 

Thanks :)

 

 

But may be worth trying a different dispenser and seeing if the results are the same.

 

Just cause its "new" does not mean that it conforms to specifications, i could have been damaged in transport, being built wrong...

 

Im still unsure why your stuck on the HTPC counts?

If you other TVC 22°/ TVC 37° are clear... these will grow most bacterium.....

 

Why are you stuck on the presence of biofilms?
Your low risk, so with through cooking any nasties will be denatured?

 

Have you tested your FP.... if your product require another kill step (cooking/reheating to core temperature +72°) i don't see the issue unless your customer has specified limits.. 

 

I guess im in the UK so may be different where you are?

What country are you from/selling to?