Q: What actions do food manufacturers need to take when a municipal boil-water advisory is issued?
In May 2010, FDA issued a guidance document titled “Use of Water by Food Manufacturers in Areas Subject to a Boil-Water Advisory.” The guidance advises food manufacturers to stop using water subject to a boil advisory and to evaluate food that was already produced with water subject to the advisory.
There are three big concerns the FDA's document addressed and we list the top questions every manufacturer should address in their plant.
1. Stop Using Contaminated Water
Once a boil-water advisory has been issued, food manufacturers should stop using the water until it meets the applicable federal and state drinking water-quality standards. In addition, any food produced with water subject to the advisory should be evaluated.
- Who is responsible at your organization for monitoring advisories?
- Do you have a plan for the water and the products if an advisory is issued?
2. Treat Contaminated Water
When a boil-water advisory is issued, it is assumed that bacterial, viral, and parasitic contamination may have occurred. Heat treatment and, where applicable, filtration can be used to reduce or eliminate the risk from this contamination.
- Do you have appropriate measures to treat and/or filter the water?
- Will the measures address water used as an ingredient and the facility’s entire water system, including that for personal consumption, cleaning, ice making, hand washing, etc.
3. Determine if Products are Contaminated
If water subject to the advisory was used as an ingredient in food or as process water and the food was not heat treated by the food manufacturer, the product may present a risk to the consumer and should not be distributed. This is unless the FDA, in consultation with the state regulatory authorities, determines that the risk is minimal and can be controlled with ordinary consumer cooking practices. FDA recommends quarantining the food until such determination has been made.
- Is there an appropriate hold/release program to cover suspect product?
- Is traceability of raw materials and finished products effective to ensure identification of all suspect products?
Other Common Concerns
Other factors addressed in the guidance document are use of water in ice, bottled water, or ready-to-eat foods; for cleaning or hand washing; or for other purposes.
Back Up Water
If you are in an area where advisories have been issued, and you are not able to treat/filter the water, it may be beneficial to evaluate a back-up water supply in order to continue operation. I have seen companies install a water-receiving line that ties into the plant’s main water supply, similar to a bulk liquid-receiving line. The companies have pre-identified suppliers that can deliver water via bulk tanker trucks.
If a back-up system is considered, you must determine how your in-plant water piping will be properly cleaned, sanitized, and disinfected to address possible contamination from the water that entered the system from the municipal source.