All places of business are subject to OSHA 1910.141—the requirement to provide clean, potable water to employees. But food and beverage facilities have additional responsibilities when it comes to protecting potable water and the products produced with it.
Regulatory Guidance for Food & Beverage Facilities
The Food Safety Modernization Act (FSMA) requires facilities to take a proactive approach to preventing contamination of food and beverage products. Your facility is likely extremely familiar with FSMA, but have you considered where potable water (and, as a result, cross-connection control) fit in?
Building an Effective Facility Water Management Program
Title 21 of the Code of Federal Regulations (CFR) 117.37 states:
Any water that contacts food, food-contact surfaces, or food-packaging materials must be safe and of adequate sanitary quality.
Plumbing must be…maintained to… provide that there is not backflow from, or cross-connection between, piping systems that discharge waste water or sewage and piping systems that carry water for food or food manufacturing.
As we often see, the regulations provide the required result, but not necessarily the process to get there. The Current Good Manufacturing Practices (CGMPs) outlined in FSMA offer more insight into what contamination prevention should look like in food and beverage facilities and across all operations.
Current Good Manufacturing Practices (CGMPs)
CGMPs require food and beverage facilities to maintain a food safety plan that prevents contamination throughout production processes. Not only do these requirements apply to your facility, but all manufacturers or providers within your supply chain must also be approved and verified under CGMPs. The key points include:
- Hazard analysis to identify “reasonably foreseeable biological, chemical, or physical hazards.”
- Preventive controls tailored to the specific hazards of each facility, written and implemented to minimize contamination.
- Oversight and management, including monitoring, corrective actions, verification, and reporting.
These elements apply to much more than potable water systems, but they might sound familiar to those well versed in cross-connection control, backflow prevention, and water management programs.
Mapping Requirements to Programs
While cross-connection control isn’t explicitly referenced or required in CGMPs, a comprehensive water management program addresses the core risks of backflow, unprotected cross-connections, and contamination of the potable water systems in a facility. The structure of effective water management programs across industries aligns with CGMP requirements.
Hazard Analysis: Cross-connection surveys help you identify risks within your potable water piping systems, inventory backflow prevention, and prioritize corrective actions to prevent contamination. Many food and beverage facilities find unprotected cross-connections with product water, process water, and clean-in-place (CIP) systems.
Often, facilities will develop backflow preventer inventories, water flow diagrams, and/or piping schematics during hazard analysis to improve documentation, maintenance processes, and ongoing program management.
Preventive Controls: When it comes to water management, procedures for ongoing, proactive prevention can include annual testing of backflow prevention assemblies, regular water sampling, flushing, filtering, and more. Make sure that whatever backflow preventers and fixtures you use align with state plumbing code and OEM recommendations.
Oversight and Management: Just like with other elements of your food safety plan, monitoring and reporting help you ensure that your water management and cross-connection control efforts are effective. Monitor things like flow rate, water temperature, disinfectant residuals, or any other identified metric specific to your facility’s operations. Many facilities conduct annual program assessments, often against established objectives, to validate program efficacy.
Ready to learn more about how HydroCorp can support your facility’s water management and cross-connection control efforts?
