What Should Food Processors Know About Their Water Supply?

By Phyllis Butler Posy, EAS Consulting Group Independent Consultant

For many food processing operations, water has become a significant constraint and, even if unacknowledged, a substantial business risk. Water supply variability, climate change, and regulatory uncertainty require today’s food processing managers to understand the condition of their water supply and take steps to ensure it does not compromise their products.

Understanding FDA and EPA Water Requirements

From a regulatory perspective, the FDA has the mandate to protect the food supply. However, based on interagency traditions, the FDA simply uses the EPA standards, under the questionable assumption that if it is good enough for drinking, it must be good enough. Thus, using EPA compliant water from a public water supply (once called “potable water”) does establish compliance with FDA requirements for many, if not most, rules (Ag Water Rule, etc.).

The EPA’s mandate, on the other hand, is the Safe Drinking Water Act which they take literally. Their risk assessments, scientific endeavors, advisories and regulations hinge on potential risk of both immediate and cumulative impacts to individuals who drink the same water supply regularly.

Their regulatory definitions, standards and classifications are based on service connections and population served. The EPA doesn’t differentiate between water systems based on volume produced; instead it classifies systems based on the number of service connections and how many of the same people are served over time. Like the recent limits on PFAS, rules usually phase in on a graduated basis, giving “smaller” systems more time to comply and a reduced testing regimen. A food plant that uses half a million gallons a day will be regarded as a single service connection and from an EPA regulatory perspective, warrants the same protection as a home.

The Devil Is in the Details

EPA focuses on a risk assessment benchmark of 1 illness in 10,000- to 1 in 1,000,000- per year as a target threshold for acceptable public health risk for drinking water and environmental exposures. This makes perfect sense for drinking water but is not as relevant for the quantity of product manufactured on even a single day by a food processor. A food manufacturer could not stay in business if their product caused one illness in 10,000 servings!

The Real State of Water

Even “stable” water systems vary. Quality fluctuates from water age and system hydraulics, and quantity varies seasonally. Supplies may seem stable today, but climate change threatens aquifers and surface water supplies alike, even “safe drinking water” systems. Many factors can impact supply without official notification or indicator changes that would alert a food safety manager to impending crisis:

• Agricultural runoff from Concentrated Animal Feeding Operations (CAFOs)
• Land fertilized by wastewater sludge amendments that concentrate PFAS or other chemical contaminants
• Leaking wastewater lagoons
• Aging and leaking infrastructure percolating into aquifers
• Severe climate phenomena like storms and floods
• Effluent from upstream wastewater treatment facilities flow downstream into drinking water intakes in more than 1 of 3 PWS that use surface water. 71% of US systems serving less than 10,000 people don’t have the treatment systems to deal with these contaminants, allowing them to pass through unmonitored –with the opportunistic pathogens (OPs) that tag along.

Some of these phenomena are occasional or even infrequent and may not show up in standard or trend analysis. If the water is used solely for processing and not as an ingredient, the impact of the contaminant load (PFAS, Microplastics, etc.) may appear trivial, further encouraging food processors to assume incorrectly that using a public water supply (PWS) alleviates any water safety concerns.

The Hidden Threat of Biofilms and Opportunistic Pathogens

However, the real threat is from the accompanying OPs and biofilm generators, often hiding in plain sight — in a “viable but not culturable” (VBNC) state. In this state, pathogens such as Pseudomonas, Salmonella and Listeria, are metabolically active and alive. They are triggered by environmental stressors to convert to a stable form that won’t attach to standard media plates and thus escape notice.

Changes in the environment promote OPs to become significant contaminants and spoilage organisms. Pseudomonas, the most prevalent genus, generates and anchors biofilms that accumulate over time particularly in processing pipes and causes the most long-term issues. Microbes communicate with each other through “quorum sensing” and signal OPs to proliferate beyond the biofilm; this increases the threat to production processes.

Pseudomonas biofilms are found in over 80% of food processing environments in dairy, meat and seafood sectors, representing significant economic losses. In addition to reducing system operational efficiency, the biofilms protect microbes and contaminants from CIP and standard sanitizing SOPs and form a breeding substrate that leads to more serious problems.

EAS Consulting Group supports food manufacturers with food safety regulatory compliance, facility assessments, and practical risk management strategies.