By Nuno F. Soares
Water is essential for life, but in many cases it is a vehicle for illness or even death. The World Health Organization estimates that contaminated drinking water causes 502,000 diarrhoeal deaths each year and at least two billion people consume and use drinking water contaminated with faeces.
It is a common misconception that diseases caused by water are exclusive to third world countries. Last year saw two cases of foodborne outbreaks related to romaine lettuce affected by E. Coli contaminated water in the United States. The investigation from the first outbreak finalized in June and five people lost their lives and 96 were hospitalized. The second contamination is still being investigated by the CDC Centers for Disease Control and Prevention. A spokesperson said “The E.coli strain was found in an irrigation reservoir. Despite the announcement, other possible sources of the outbreak are still being investigated. As of December 13, 2018, 59 people in 15 states and Washington D.C. have been infected by the strain of E.coli.“
There is no food safety system/standard or guideline that does not include the need to manage water—from the Codex Alimentarius Code of Practices to SQF, BRC, IFS, ISO 22000, and FSSC 22000.
Additionally, in many countries, regional and state water boards enforce water quality management programs.
Here are six steps to consider when implementing a water quality control system.
Define sources and purposes
When planning to develop a procedure to control water quality it is important to define the sources of water and the purpose it will be used for. See the below diagram for examples.
The source of the water is important to characterize its “base” quality. When the source is municipal/city water it is often treated. In some countries you can even access their tests results. When the organization collects the water directly from rivers, wells, lakes, or rainwater a treatment must be in place. The organization must also see itself as a water supplier operator and guarantee potable water at the point of entrance. Some of the most common options to treat water in the food industry are chlorin, ozone, ultraviolet light, and reverse osmosis. In many cases, the food industry uses these treatments even when using a potable water supply.
Another important aspect is the intended use. Will the water directly contact food products (e.g. ingredient, steam, or ice) or not (e.g. cooling or heating)? In the case of steam and ice, cleaning and maintenance of the equipment must also be planned, implemented, and monitored. Water used in cleaning has also to be managed depending if it is for personnel hygiene (e. g. showers or hand washing), or for cleaning non-food contact surfaces or food contact surfaces. It is also recommended to study how water characteristics may influence the effectiveness of cleaning agents.
Water system description
a) Water system diagram
It is important to have a complete diagram of the water system. Refer to the below example diagram.
b) Amount of water needed (and water pressure)
The organization must assess and calculate its needs in terms of volume of water and pressure. This is important to guarantee that water is always available and with adequate pressure.
I have witnessed situations in organizations where in some water consumption spike periods, water was not available in toilets or very low pressure in cleaning areas. The volume of water needed is also detrimental to correctly design water treatments equipment (when used) or even sampling periodicity.
c) Amount of wastewater produced
The wastewater produced should drain easily and avoid water accumulation. Therefore, the organization should evaluate the amount of water that is wasted daily to guarantee that is compatible with the draining capacity. The organization can consider re-using wastewater to reduce water consumption.
d) Water pipe materials
The materials used in pipes where potable water circulates must be appropriate so their components do not constitute a migration hazard or introduce any kind of flavor or smell.
e) Drains and wastewater pipe materials
The organization shall guarantee that drains and wastewater pipe materials are appropriate and resistant to chemicals used during cleaning.
Manage documented information
a) Statutory and regulatory requirements
The organization must search for and retain all statutory and regulatory requirements applicable according with the sources and purposes defined in point one. Organizations must also comply with regional and country regulations and be aware of international codes or guidelines.
b) Maintenance planning
The water system shall be included in the organization maintenance plan, which includes, where appropriate:
- Water treatment equipment
- Water treatment consumable materials (lamps, filters, etc.)
- Back-flow prevention devices
- Water taps
- Water pressure equipment
- Water quality monitoring devices
- Other water systems
c) Preventive and corrective maintenance records
Records from any maintenance in the water system shall be retained as evidence and to be considered in the continual improvement of the system. Examples of these situations can be repaired using a chlorine injection pump or an ultraviolet lamp.
d) Water system verification (inspections)
The organization should complete a full inspection of the water system infrastructure at least annually. At minimum, the inspection should include a pipe deterioration assessment, backflow prevention device operationality (consider pressure tests), and water-collecting infrastructure and their surroundings.
a) Water quality analysis (for each source)
As a starting point, the quality of the water delivered or collected must be known. The quality can be determined by conducting/requesting analysis and research on how the surroundings (e.g. pollution, soil contamination by agriculture/livestock practices) and soil constitution can affect water quality. Organizations must also consider variations on water quality throughout the year and seasonal human and animal activities such as contamination and pollution.
b) Hazard analysis throughout the entire water system
To proceed to the hazard analysis of the water system, the organization needs to gather a multidisciplinary team to assess each step of the processes. This team may include external experts including trained personnel from the water supplier, water analysis laboratory, or the water treatment equipment. EN 15975-2 provides an excellent guideline for water risk management incorporating elements from the Water Safety Plan. The approach, in essence, is similar to that of hazard analysis, which food safety professionals are familiar with for HACCP.
Define monitoring program
This is important even if you are not using a third-party certified laboratory.
a) Define microbiological and chemical parameters and sampling
The organization shall follow a code of practice based on statutory and regulatory requirements and expert advice in respects to compliant parameters to monitor and appropriate sampling. Installing sampling ports should be considered as long as they do not introduce a hazard such as stagnant water.
b) Establish an annual timeline monitoring form
In order to visualize what you need to do to comply with the water quality monitor program, it’s advisable to develop an annual timeline. The timeline should include:
- What to monitor (parameters)
- Where to monitor (places)
- When to monitor (day/week)
- Who is responsible for sampling, analysis, and any corrective actions
c) Retain similar information (complete lab analysis reports) when using an external laboratory
When the water monitoring control plan is developed and managed by an external laboratory, the organization should retain the information necessary for a. and b.
d) Communicate results
According to the local regulatory requirements, the organization may be required to share the results of the water monitoring control plan with official authorities and/or others inside the organization.
a) Who monitors results
Responsibility for receiving and analyzing results from the monitoring program must be defined so that any nonconformity or trend to nonconformity can be detected and reported. This person shall have appropriate competence/training and ideally be a member of the team defined in 4 b.
b) Who analyzes nonconformity
If a nonconformity is identified, it must be addressed promptly by a competent individual. This person must also have defined responsibility/authority to initiate corrections and corrective actions.
c) Have in-place effective corrections in the case of nonconformity
The organization shall define actions to conduct in the case of nonconformity. When a nonconformity is detected, the organization should be prepared to implement corrections. This means that it shall consider in advance, at least:
d) Risk assessment re-evaluation and improvement
The organization should re-evaluate its water system risk assessment at least annually. Results for monitoring procedures, inspections to the system, or laboratorial analysis and their trends can be used to assess the efficacy of the system and identify necessary improvements. Procedures need to be in place to regularly verify new statutory or regulatory requirements.
About the author
Nuno Soares is a food engineer who has been working in food industry since 1999. Nuno has worked in roles including quality and production manager. With the goal of reaching further with his ideas for food safety and support other professionals in their daily work, Nuno recently embraced researching and publishing activities. For his PhD, he researched how to improve frozen fish shelf-life and protection by developing a new glazing solution. After publishing his first book Food safety in the Seafood Industry (Wiley), he recently self-published the e-book: ISO 22000:2018 Explained in 25 diagrams.
You can contact Nuno on LinkedIn or at firstname.lastname@example.org.