This article is written to meet the following sections of the Standards:
|BRCGS Food Safety Issue 8||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||220.127.116.11 Air|
4.9.10 Compressed air and gases
|SQF Edition 9||11.5 Water, Ice, and Air Supply|
Product contact 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.
All water, including ice and steam, must be potable and 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 handwashing.
- It’s used for cleaning of equipment that comes into contact with product.
Water which doesn’t come into contact with the product, should be suitable for the task. It doesn’t need to be potable or treated – unless there’s 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 based on risk and completed at least annually.
The microbiological and chemical quality of water must be analysed to prove that it’s potable.
The potable water must tested for conformity to local legislation, or in the absence of any legislation it must comply with World Health Organization (WHO) Standards for drinking water.
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.
Have you ever wondered why you’re always asked for site plans on an audit? You spend time drawing out the site layout and then drawing loads of arrows and lines on there, to depict the routes for waste, people, product, drains and water etc… But why do you do it?
Most of us would probably admit that we never use these plans for anything, it’s just something that we get out when we’re audited – so what’s the point of them?
Water schematics actually do have a purpose, let’s look at what they’re for.
The purpose of the water schematic is to:
- To establish where the water comes into the site and therefore where the water infeed filter should be.
- Identify and map out all the water pipework leading off from this main infeed pipe, which allows the identification of:
- Any dead legs in the system.
- The furthest points in the water system.
- All the water output points.
A dead leg is a water pipe which once supplied water to a part of the factory that’s capped off. For example, where a handwash sink is removed, the water pipe is no longer needed and so, engineering come along and cap it off. This means that there’s still water held in this pipe, which no longer goes anywhere – so it just sits there and stagnates. This stagnant water can then contaminate the mains water at the point at which the pipe connects to the main ring main.
Here’s a real-life example from a site which had high TVC levels in their water. They very kindly gave us permission to use their schematic as an example case study – as it’s a good example of how you can unknowingly create a dead leg.
Example water schematic
The site had recently removed a line from one of their units, in order to increase their storage capacity. During this process, they removed a sink from the area that wasn’t needed. The mains water comes in where the pink diamond is shown, and the blue lines show the direction water travelling around the site.
The sink was capped off at the point where the sink was, rather than removing the pipe back to the point where it meets the main ring main.
This means that the water in this pipe can’t go anywhere, so it sits there and stagnates. This then contaminates the water in the ring main, which is then picked up in the results of the water sampling micro.
Make sure that when old equipment is removed that requires water, that the water pipework is removed and it’s capped back at the ring main. If you have high results on your water micro, check your water schematic to make sure you’ve not got any historic dead legs.
Let’s use our example water schematic again to explain this.
The water in the ring main (the pipework that allows the water to go round and round) is constantly supplying other parts of the factory and it’s always on the move, so it’s unlikely that it’ll stagnate and become a micro problem.
Where the pipework is routed away from ring main, you need to follow each route to see where it goes. The furthest part of the pipework away from the ring main, is where the water is most at risk.
Water output points
The water output points at the end of these routes, must be on the water sampling plan. That way you’re confirming that all the water on that route is potable (safe to drink). So, check your water schematic to make sure that all of your pipework furthest away from the ring main is being sampled, at the very least at the very end output point.
Potable water sampling plan
Using the risk assessment and the water schematic, a sampling plan must be defined to prove that the water is potable.