1600 South Jackson Street Seattle, Washington 98144 Phone 206‐323‐3540 Fax 206‐323‐3543 SETTING THE STANDARD IN SEAFOOD SAFETY
WATER, STEAM AND AIR SOURCES
Technical Bulletin SOP-09
Processors are required by regulation to ensure the safety of water and air sources used for food processing. All utilities to and within the production and storage areas shall be designed, constructed, maintained and monitored to effectively control the risk of product contamination.
All water used for the preparation of product, or for equipment or plant cleaning shall be supplied in sufficient quantity, and be potable or pose no risk of contamination. The microbiological and chemical quality of water, steam, ice, air, compressed air or other gases that do not constitute an ingredient but come in direct contact with food or packaging shall be regularly monitored at a frequency based on risk assessment that ensures their safe and suitable use in food manufacturing.
Water: Municipal water supplies are subject to local requirements for sanitary and potable conditions. The water supplied by municipalities is required to be potable, i.e. safe for direct consumption. Utilities are required to test their water supplies against chemical and microbiological criteria to ensure potability. Test results from the utility companies are generally available upon request. It is advisable to obtain these results periodically as a verification procedure. Utilities are also required to provide public notice to their customers when water is not of required potability. In addition to the utility company requirements, food manufacturers in the United States are required to comply with Good Manufacturing Procedures (GMPs in 21 CFR 110) and Sanitation Standard Operating Procedures (SSOPs in 21 CFR 123) that provide additional assurance of quality and safety of water, ice, and steam. The testing regimen, advisory systems, and regulatory requirements should all be considered when analyzing the risk of public safety arising from the manufacturer’s use of the water supply. Regulatory requirements also apply to private water sources. These prerequisites would appear to minimize the risk for compliant water sources used at a manufacturing facility for domestic, processing, steam, and ice making purposes. Manufacturers of products that will be distributed internationally should also ascribe to the Codex Code of Practice General Principles of Food Hygiene that states:
An adequate supply of potable water with appropriate facilities for its storage, distribution and temperature control, should be available whenever necessary to ensure the safety and suitability of food. Potable water should be as specified in the latest edition of WHO Guidelines for Drinking Water Quality, or water of a higher standard. Non-potable water (for use in, for example, fire control, steam production, refrigeration and other similar purposes where it would not contaminate food), shall have a separate system. Non-potable water systems shall be identified and shall not connect with, or allow reflux into, potable water systems.
Revision Date: 6-10-08 Supersedes: Technical Bulletin SOP-09, 4-16-08
www.spa‐food.org 1 Cont. Water, Steam and Air Sources
Steam: When steam comes in direct contact with food or direct food contact packaging, it is important to ensure that all constituents of the steam are safe and suitable for such use. In addition to a potable water source, chemicals used for boiler treatment should be specifically authorized for use for direct food contact application when applicable. For example steam used headspace injection to create vacuum in canned products. Authorization may be in the form of: • Documentation verifying the chemicals have a USDA ID number of G-6, which would be a food contact approved chemical. • Compliance with US regulation 21 CFR 173.310 - Boiler water additives. • Other evidence of the safety and legality of the chemicals used for boiler treatment. Processors should also have a Sanitation Standard Operating Procedure (SSOP) in place that verifies appropriate application of the approved treatment chemical.
Air: Food manufacturers that are regulated by the US Food and Drug Administration must comply with GMPs, including those in 21 CFR 110.40(g) as follows: (g) Compressed air or other gases mechanically introduced into food or used to clean food-contact surfaces or equipment shall be treated in such a way that food is not contaminated with unlawful indirect food additives. SSOPs in 21 CFR 123 provide additional requirements that would ensure the safety of the air supply used by: (5) Protection of food, food packaging material, and food contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate, and other chemical, physical, and biological contaminants; Regulations in 21 CFR 123 include requirements for monitoring and documenting SSOPs.
Given the numerous regulatory requirements for the control of water, steam, ice, and air in a food processing facility, there would be no significant risk to product safety or quality for compliant companies. Companies should use GMP and SSOP monitoring records, product spec sheets (for boiler chemicals), and utility records (for public sources) as affirmative evidence of compliance.
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