The standards

This article is written to meet the following sections of the Standards:

BRCGS Food Safety Issue 9 4.5 Utilities
BRCGS Packaging Issue 6 4.3 Utilities
BRCGS Agents & Brokers Issue 3 Not applicable
BRCGS Storage & Distribution Issue 4 9.3.1 X Product contact utilities
4.4.4 XD Water
FSSC22000 Version 5.1 No specific clauses
IFS Food Version 7 4.9.8.3 Air
4.9.9 Water
4.9.10 Compressed air and gases
SQF Edition 9 11.5 Water, Ice, and Air Supply

The requirements

Product gas and air

Where air and other gases are product contact or used as a material in the finished product, they must not pose a risk of contamination, this must include:

  • Supplier management; approval for using specifications and certificates of conformance.
  • Filtration of compressed air, including risk assessment to determine the required filter size.
  • Risk assessment which includes equipment manufacturers guidelines, to determine if and how often the gas or air must be microbiologically tested to prove that it’s safe.

 

Water

Water management system

All water, including ice and steam, must be potable, provided in sufficient quantities where:

  • It’s a material that’s used to make the product.
  • It comes into contact with the food or food contact packaging during processing.
  • It’s used for hand-washing.
  • It’s used for cleaning of equipment that comes into contact with product.

Water which does not come into contact with the product, should be suitable for the task. It does not need to be potable or treated, unless there is a risk of it coming into contact with materials, product contact equipment or the product itself.

Potable water risk assessment

The frequency of testing must be increased be based on risk, and completed at least annually. The risk assessment must take into account:

  • Local legislation requirements.
  • Historical incidents with the potability of the water.
  • Previous local issues, for example if the region has high levels of nitrate.
  • If the water is bore-hole.
  • Any specific site concerns, such as how long the water is held in storage or the use of lead pipes.
  • Where the water is treated to make it potable.
  • The quantity used and therefore the scale of impact if there was an issue.

The microbiological and chemical quality of water shall be analysed to prove that it is potable.

Water schematic

A schematic diagram of the water distribution system on site, must be in place. This must include holding tanks, water treatment and water recycling steps. The diagram must be used to determine the water sampling plan, and also to manage water quality.

Potable water testing

Water testing must be based on risk, taking into consideration:

  • Testing the points of use at the far end of the circuit, as shown by the schematic.
  • The source of the water.
  • Water storage and distribution facilities.
  • Where the water is used and what for.
  • Historical results of water testing.

BRCGS Food Safety Issue 9

4.5.1      This clause has been updated to state that stored water and water handling systems must be managed to minimise risk. Water sampling plans must now also be based on legal requirements.  The interpretation has also been expanded to state that the water must be fit for purpose and that the testing of it must consider legal requirements. Where water storage systems are in use, the risk assessment must take into account risks posed from the equipment itself.

4.5.2      The source of the water has been added to this clause.

Want to implement this topic into your QMS?

This article is part of a series on the subject of contamination control. If you’d like compliant documentation for your management system on this subject, we recommend you purchase our pack.

Contamination control

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Contamination control is one of the most important prerequisite controls, to support the Product Safety Plan. It controls the risk of cross-contamination of physical, chemical and microbial contamination from equipment, tools and utilities used in product areas.

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