Water is one thing that most of us take for granted. You turn on the tap and get clean, fresh water. This is not, however, something that applies around the world. There are places where clean water is a rarity and waterborne diseases such as cholera are common. But, even in a nation like the United States where clean water is the norm, problems do crop up. Look at the lead problems in Flint, Michigan from a few years back. And in 1993, we had the following outbreak, as reported in Morbidity and Mortality Weekly (1994, Vol. 43:36):
In March and April 1993, an outbreak of cryptosporidiosis in Milwaukee resulted in diarrheal illness in an estimated 403,000 persons. Following that outbreak, testing for Cryptosporidium in persons with diarrhea increased substantially in some areas of Wisconsin; by August 1, 1993, three of six clinical laboratories in Dane County were testing routinely for Cryptosporidium as part of ova and parasite examinations. In late August 1993, the Madison Department of Public Health and the Dane County Public Health Division identified two clusters of persons with laboratory-confirmed Cryptosporidium infection in Dane County (approximately 80 miles west of Milwaukee).
This particular incident has had a lasting effect on how FDA expects food processors to assess risk; that is, there is an expectation that Cryptosporidium parvum will be evaluated as part of a company’s hazard analysis of water. This parasite is resistant to chlorine; a combination of chlorine and microfiltration is needed to ensure the safety of water. The Wisconsin systems lacked the latter.
So, each and every food processor must establish programs to manage the water that they utilize in their daily operations. Think about all the different ways water may be used in a food processing facility. Potential applications include but aren’t limited to the following:
- Cleaning and sanitizing;
- Steam generation or heating (with direct product contact);
- Transport of foods;
- Waste disposal; and
Water as a HACCP Prerequisite
FDA’s HACCP regulations for both the juice and seafood industries include eight areas where processors must have documented programs to assure good sanitation. One of these emphasizes the safety of water and ice used in food processing. The following has been drawn from the FDA HACCP regulation for the juice industry found in 21 CFR Part 120:
§120.6 (a) Sanitation controls. Each processor shall have and implement a sanitation standard operating procedure (SSOP) that addresses sanitation conditions and practices before, during, and after processing. The SSOP shall address: (1) Safety of the water that comes into contact with food or food contact surfaces or that is used in the manufacture of ice.
As part of any inspection, FDA will examine the programs that the regulated industries have established to ensure the safety of water.
USFDA’s Current Good Manufacturing Practice Hazard Analysis and Risk Based Preventive Controls for Human Food regulation (21 CFR Part 117) expands on this and emphasizes the importance of water in a food processing facility as follows:
§ 117.37 (a) Water supply. The water supply must be adequate for the operations intended and must be derived from an adequate source. Any water that contacts food, food-contact surfaces, or food-packaging materials must be safe and of adequate sanitary quality. Running water at a suitable temperature, and under pressure as needed, must be provided in all areas where required for the processing of food, for the cleaning of equipment, utensils, and food-packaging materials, or for employee sanitary facilities.
(b) Plumbing. Plumbing must be of adequate size and design and adequately installed and maintained to:
- Carry adequate quantities of water to required locations throughout the plant.
- Properly convey sewage and liquid disposable waste from the plant.
- Avoid constituting a source of contamination to food, water supplies, equipment, or utensils or creating an unsanitary condition.
- Provide adequate floor drainage in all areas where floors are subject to flooding-type cleaning or where normal operations release or discharge water or other liquid waste on the floor.
- Provide that there is not backflow from, or cross-connection between, piping systems that discharge wastewater or sewage and piping systems that carry water for food or food manufacturing.
Let’s look at what the regulation is mandating. The water supply must be adequate for all uses of the operation and must be derived from an adequate source. This can be interpreted as follows: Not only must there be enough water to meet all the needs of the processing facility, but the plumbing system must be able to handle all wastewater and sewage that is reasonably likely to occur.