11

Water and HACCP Programs

YU-PING WEI and JAMES SWI-BEA WU

National Taiwan University, Taipei, Taiwan
PHILIP CHENG-MING CHANG
National Taiwan Ocean University, Keelung, Taiwan

I. INTRODUCTION
Water is used to produce, process, and under certain conditions store food. Water is also
used as an ingredient in many processed foods. Contaminants can find their way into food
products via water as a carrier. Therefore, the quality of water influences the quality of
food greatly. Only potable water should be used in food handling, formulation, and pro-
cessing, except for steam production, operations where water is not in contact with food,
and in certain processes provided that direct contact between water and food does not
constitute a hazard to safety, e.g., chilling with clean seawater [1]. Potable water should
meet the specifications in World Health Organization (WHO) or U.S. Environmental Pro-
tection Agency (EPA) guidelines for drinking water quality. Some of the key values are
listed in Table 1.
Natural water must be properly treated to meet drinking water standards. Water can
also be recontaminated during storage and distribution. It is necessary to implement a
sanitation standard operating procedure for water management in every food processing
plant. Control should be established to prevent contamination from water to food products.
The hazard analysis and critical control point (HACCP) system is often applied for this
purpose.

II. WATER AS A HAZARD SOURCE

There are three major sources of contaminants in water used in food plants: contaminants
in water source; residues of additives or contaminants formed during water treatment,
© 2003 by Marcel Dekker, Inc.
 Table 1 Some Key Values for Drinking Water Guidelines
Parameter WHO EPA
Color point/color scale 15 15
Turbidity, nephelometric turbidity unit (NTU) 5 5
Total dissolved solids, mg/L 1000 500
pH 6.5–8.5 6.5–8.5
Magnesium (as Mg), mg/L — 0.05
Sodium (as Na), mg/L 200 —
Iron (as Fe), mg/L 0.3 0.3
Manganese (as Mn), mg/L 0.1 —
Chloride (as Cl), mg/L 250 250
Fluoride (as F), mg/L 1.5 2.0
Sulfate (as SO 4), mg/L 250 250
Nitrate (as NO 3), mg/L 50 10
Copper (as Cu), mg/L 1.0 1.0
Cadmium (as Cd), mg/L 0.003 0.005
Selenium (as Se), mg/L 0.01 0.05
Mercury (as Hg), mg/L 0.001 0.002
Arsenic (as As), mg/L 0.01 0.005
Lead (as Pb), mg/L 0.01 0.015
Zinc (as Zn), mg/L 3 5
Chromium (as Cr), mg/L — 0.1
Cyanide (as CN), mg/L 0.07 0.2
Aluminum, mg/L 0.2 —
Boron, mg/L 0.5 —
Alpha emitters, Bq/L 0.1 0
Beta emitters, Bq/L 1.0 0
Fecal coliform, counts/mL 0 0

Source: Adapted from Refs. 4 and 40.

storage, or distribution of drinking water [2]; and cross-contamination during processing

especially in reused or recycled water [3]. Water for food processing should be routinely
analyzed for its quality. The elements of the analysis of water are listed in Table 2. Many
of the listed items are used as a sanitary index or a measure of potential hazards.

A. Chemical Hazards
Chemical components in drinking water to be assessed for health risk include inorganic
and organic compounds, pesticides, disinfectants, and disinfectant byproducts [4]. Natu-
rally occurring contaminants are predominantly inorganic compounds such as arsenic and
manganese, which are derived from natural mineral formations. Organic compounds, like
pesticides, disinfectants, and disinfectant byproducts are usually introduced by human
activity [2].
Several of the inorganic contaminants have beneficial as well as adverse effects.
Trace elements like copper, iron, manganese, molybdenum, selenium, and zinc are exam-
ples. On the other hand, lead from lead piping and plumbing and nitrate from intensive
agricultural activities are usually harmful [2].
© 2003 by Marcel Dekker, Inc.
Table 2 Elements of the Analysis of Water
Water Physical–chemical Undesirable Toxic
characteristics properties components components Hazardous organisms
Scent PH Nitrate Arsenic Salmonella spp.
Color Conductivity Nitrite Cadmium Escherichia coli
Turbidity Chloride Ammonia Cyanide Pseudomonas aeruginosa
Sulfate Oxidation Chromium Streptococcus D
Calcium Iron Mercury Coliforms
Aluminum Magnesium Nickel Aerobic mesophiles
Hardness Copper Lead
Dry residuum Zinc Antimony
Phosphorus Pesticides
Suspended Aromatic
particles hydrocarbons

Pesticides can reach ground or surface water by leaching or run-off following normal
agricultural practices or by accidental spills [5]. Conventional drinking water treatment
cannot remove many of these agricultural chemicals adequately because it was not spe-
cifically designed for this purpose [2]. Disinfection of drinking water often involves the
use of very reactive chemicals such as chlorine, which has been the most important disin-
fectant for decades, or ozone, which is becoming more popular now. These compounds
may react with many organic micropollutants in drinking water and thus give rise to disin-
fection byproducts.
Food products may be contaminated by disinfectants that are used in cleaning but
not thoroughly removed afterward. Or they may be contaminated from cooling water if
the water is not properly treated. The metals that came from piping, plumbing, and equip-
ment may also contaminate food [6].
B. Biological Hazards
Freshwater carries indigenous microorganisms, including bacteria, fungi, protozoa, and
algae. A few among them are known to produce toxins and cause or transmit diseases.
The pathogenic microorganisms include Salmonella spp., Vibrio cholerae, Shigella spp.,
Cryptosporidium parvum, Giardia lamblia, Cyclospora cayetanensis, Toxiplasma gondii,
some strains of Escherichia coli, etc., and the viruses such as Norwalk and hepatitis A
viruses [7].
Water in distribution system may be contaminated by pathogenic bacteria, fungi,
yeasts, protozoa, etc., that come from back-siphonage or have grown in dead ends [8,9].
Iron bacteria, whose sheaths contain ferric hydroxide, may gum up an entire water supply
and are difficult to eliminate. Efficient filtration greatly reduces the microbial load, but
filters themselves may sometimes be a source of bacterial contamination of the water. For
instance, filters in the treatment of water for making soft drinks have occasionally been
found to contribute large numbers of coliform bacteria [10,11]. The two main sources of
bacteria in drinking water distribution systems are bacteria grown in and sheared from
the biofilm and those carried over from the water treatment process [9].
Water may be in contact with food products after heat treatment. The microbiologi-
cal quality of this water, especially if the foods are ready-to-eat types, should not only
be free from pathogens (like drinking water), but also be low in (if not free from) spoilage
© 2003 by Marcel Dekker, Inc.
 bacteria, such as Pseudomonas, Alcaligenes, and Flavobacterium [7]. This is particularly
important for foods to be kept at low temperatures. When water is used as one of the
ingredients or as a process aide, there will be certain specific microorganisms that deserve
concern. Anaerobic gas formers may enter foods from soil-laden water. The gas-forming
coliform bacteria may enter milk via cooling tank water and cause trouble in cheese mak-
ing. Bacteria that cause ripeness of milk, e.g., Alcaligenes viscolactis and Enterobacter
aerogenes, usually come from water, as do slime-forming species of Achromobacter, Al-
caligenes, and Pseudomonas, which sometimes cause trouble in cottage cheese. Cannery
cooling water often contains coliform and other spoilage bacteria that may enter canned
foods during cooling through minute defects in the seams or seals of the cans. This water
commonly is chlorinated, but there have been reports that chlorine-resistant flora can build
up over a certain time period. Insufficient cooling could result in thermophilic spoilage;
excessive cooling could result in postprocess contamination due to leakage of corroded
cans. The bacterium causing the surface taint of butter, Pseudomonas putrefaciens, comes
primarily from water. The bacterial flora of crushed ice to be applied to fish or other foods
consist mostly of Corynebacterium, Alcaligenes, Flavobacterium, Pseudomonas, and
cocci [6].
The ice or water used for chilling products, such as chicken at the final stage of
processing, can be a source of cross-contamination of a large number of birds from a
single bird contaminated with an enteric pathogen [12,13]. Similarly, the warm water used
in defeathering chickens can be a source of thermoduric bacteria [7]. Furthermore, reuse
of water to cool continuous loads of produce increases the risk of cross-contamination.
For example, contaminated produce from a single container going through a cooling pro-
cess may result in the build-up of pathogens over time in the cooling water supply [3].

C. Physical Hazards
A suspended particle in water generates at least two types of problems: first, it can carry
bacteria adhered on its surface and protects them from disinfection [13a,14]; second, it
contributes to the formation of loose deposits in reservoirs and pipework, which are resus-
pended into the water phase when a change occurs in the hydraulic properties of the
system (direction, velocity, water hammer, etc.) [15]. In distributed water, the number of
suspended particles is usually quite low [16]. The composition of loose deposits has been
determined and shown varying proportions of iron and manganese oxides, sand, zinc floc,
algae siliceous skeleton, detrital organic particles, and micropollutants [15,17,18].
Sand, stone, and dirt resulting from washing vegetable or fruit and debris from
equipment corrosion or breakage are the most commonly found physical hazards in process
water [19]. However, a properly designed water treatment procedure is usually sufficient
to remove or detect harmful physical materials by means of sedimentation, screening,
centrifugation, or metal detection devices. Therefore, potential physical hazards presented
in water are usually not significant enough to be dealt with individually.

III. WATER HAZARD MANAGEMENT

The aim of water management is to develop and maintain healthy water systems that
guarantee sustained use. Proper equipment design and software management is a good
way to control water safety. Through built-in antipollution features and a user-friendly
self-diagnostic software interface, ideal water treatment equipment can avoid unplanned
© 2003 by Marcel Dekker, Inc.
 contaminations to occur from careless human handling errors. Hardware itself can never be
error-free. It depends on properly designed standard operation procedures and monitoring
routines to prevent any error from happening.
Water contaminants from various sources are discussed in the following sections.

A. Water Source
Food plants should have an easy access to water supplies in good quality and sufficient
quantity. Criteria for choosing water supply vary with the geographic location and cost
considerations. Potable, underground, and surface water are three common water sources
for food production. Each source has its own hazardous characteristics.
Potable water, which has previously been treated to meet drinking water standards,
does not need to go through further treatment for amending its quality except to be used
in the production of some special products such as carbonated beverages, which usually
requires the water to softer. The quantity of water available to a food plant depends on
the capacity of piping systems and other variables such as water pressure or pipe leakage.
Most food companies are equipped with their own water storage facilities for emergent
needs [20].
When using underground water for food production, the supply is usually sufficient,
and large storage tanks are not needed. The quality of underground water is mainly deter-
mined by the location and the depth of the well. Underground water generally goes through
some natural filtration processes that result in less contaminants and higher mineral con-
tent. Intended use determines if a demineralization treatment is necessary. In recent years,
the concern over the contamination from industrial dumps, agricultural pesticides, and
human activities has limited the use of underground water without cautious purification
treatments followed by constant monitoring of the quality [21].
Surface water from rivers or lakes is the most convenient source of water, while at
the same time the most unstable one in terms of the variation in quality and quantity, as
affected by season, climate, and the environment. Because of the direct exposure of surface
water to biological and chemical pollutants, hazards from this origin should be watched
for carefully. Therefore, surface water should never come into contact with foods unless
it has been adequately purified.
The supply of water should be planned to meet the peak water demand of the food
processing facility. In practice, two sets of parallel water treatment systems, or a set of
a backup system in addition to the main system, are suggested to keep the supply of water
uninterrupted while maintenance or repairing work is undertaken [20].

B. Water Treatment and Distribution Systems

Though it is designed to remove impurities and safeguard the water supply, water treat-
ment systems without proper maintenance can be a potential source of contamination
[22,23]. Modern water treatment equipment also includes sensors, detectors, or controllers
that continuously monitor the water quality. These automated devices can detect or control
water pressure, water flow velocity, alkalinity, as well as the residual disinfectant content
in a piping system. In a computer-aided automatic water treatment system, accurate in-
line monitoring and controlling of water quality can be achieved and the chance for water
safety failure from human error is greatly reduced. However, scheduling for inspection and
maintenance service, including calibration of sensors, timers, or feeding pumps, becomes
© 2003 by Marcel Dekker, Inc.
 necessary to prevent the occurrence of failures of the system. Moreover, the person in
charge should keep complete records of service and inspection.
Plumbing systems and hoses conveying water should be made of approved corro-
sive-, alkaline-, and acid-resistant materials. Cross-connection between drinking water and
non–drinking water systems should be prohibited. It is advisable that non–drinking water
piping systems shall be durably identified to be readily distinguishable from drinking water
systems. A backflow prevention design should be installed to prevent reverse contamina-
tion of water reservoirs or tanks from handwashing or service sinks. These devices include
air gap or backflow (back-siphonage) prevention valves or altitude control design.
Devices such as water treatment equipment or backflow preventers shall be sched-
uled for inspection and service in accordance with manufacturer’s instructions and as
necessary to prevent device failure based on local water conditions. Routine inspection
of microbial, alkalinity, and residual chlorine of the water supply is important. A routine
microbial check of potable water every six months is normally adequate, but should be
more frequent, such as once per month, for water from other sources. Alkalinity and
residual chlorine are easier to be measured, and more frequent inspections are recom-
mended [20].

C. Water for Food Processing

Included in this category are washing water, rising water, chilling water, cooling water,
etc. The required quality of water may vary depending on where along the chain of pro-
cesses the water is used. While water quality management may vary throughout all opera-
tions, packers should follow good manufacturing practice (GMP) to minimize the potential
for the introduction or spread of pathogens via processing water. Water that meets the
microbial standards for drinking water is considered safe and sanitary.
The use of chemical disinfectants ought to be in accordance with national or regional
laws or regulations. Operators should carefully read antimicrobial chemical labels, regula-
tions, and other relevant information. Operators should follow manufacturers’ directions
for correct mixing of antimicrobial chemicals to obtain efficient concentrations and to
minimize safety hazards. Operators should not add antimicrobial chemicals in wash water
to reach a concentration higher than the allowable level. Antimicrobial chemical levels
should be routinely monitored and recorded to ensure that they are maintained at appro-
priate concentrations. Other parameters, such as pH, temperature, and oxidation–reduction
potential, which indicate level of active agents or those factors affecting the effectiveness
of the antimicrobial agents, should also be monitored and recorded. Surfactant treatments
with some antimicrobial chemicals may need to be followed by a clean water rinse to
remove any residues.
If hot water is used for cleaning purposes, temperature should be monitored. Periodic
changing or cleaning of screens and filter assembles is important to maintain sanitary
conditions for the reconditioning of washing water.
The benefits of chilling to remove field heat and the temperature requirements for
optimal keeping quality vary for different types of produce. Maintaining temperatures
that promote optimal product quality may reduce the risk of microbial hazards. Chilling
equipment, such as hydrocoolers, and containers holding produce during chilling opera-
tions, should be clean and sanitary. Field soil should be removed as much as possible
from produce and containers prior to chilling [24].

© 2003 by Marcel Dekker, Inc.

 D. Reused or Recycled Water
Washing water recycled for food product usage is generally not acceptable because of its
highly polluted nature. If its utilization is inevitable, complete removal of impurities and
pathogens by means of filtration, disinfection, or heating is necessary.
In any case, reused water should be subjected to reconditioning to meet certain
microbiological as well as chemical and physical criteria on drinking water specifications
before its use. It is recommended for the processor to adopt performance parameters for
monitoring and testing programs to assure that the water is reconditioned and maintained
free of pathogens. Appropriate performance parameters may include temperature control
and microbiological tests. Visible solids should be removed before reuse. No sanitary
nuisance should be allowed. Testing for total bacterial counts, total coliforms, fecal coli-
forms, coagulase, Staphylococcus aureus, Listeria monocytogenes, Legionella spp., and
other related pathogens should be considered for validation purposes. Testing for chemical
oxygen demand (COD) or similar tests may also be performed. During storage, there
should be no microbiological carryover of reused water from one day to the next unless
the temperature is maintained at or above 63°C (145°F) by automated means. The intended
use of the water determines the chemical quality required. For instance, if the water is
reused for disinfecting or cleaning, it should not contain substances in amounts that affect
the efficiency. Recycled water should have a separate distribution system that is readily
identifiable [25].

E. Steam Supply
Steam coming into direct contact with food or food-contact surfaces should be generated
from potable water with no harmful substances added. Steam supply should be sufficient
for operational requirements. The use of boiler treatment chemicals ought to be in accor-
dance with national or regional laws or regulations.

F. Ice Supply
Ice as an ingredient or in direct contact with food should be made from potable water
and be properly manufactured, handled, and stored to avoid contamination. Microbial
testing of water for ice making ought to be performed periodically to ensure its clean and
sanitary condition. If the ice is purchased from a supplier, the food plant operator should
ask the supplier for information about the ice-making plant and the routine inspection
records of this product. It is advisable to keep these records on file. Equipment for the
manufacture, transportation, and storage of ice should be in sanitary condition. Water in
hydrocoolers should be changed as needed to maintain the quality. Interiors of hydrocool-
ers should routinely be cleaned and sanitized [20].

IV. CONTROL OF WATER HAZARDS

A. Critical Control Point
As mentioned, water used for culinary purposes or in direct contact with food materials
should meet drinking water standards. As a common practice in the food industry, the
quality of processing water is constantly monitored and controlled by sanitation standard
operation procedure (SSOP) or GMP programs. An operation that may affect the shelf-

© 2003 by Marcel Dekker, Inc.

 life of a food product is regarded as a critical control point (CCP). Water may be involved
at a CCP either by acting as the means for reducing the microbial load of a raw material
in such treatments as washing or cleaning in the processing for fresh or minimum pro-
cessed foods or by acting as a heat exchange medium in contact with an in-process or
final product. The water used in these instances should receive especially stringent quality
control. Examples are the washing water in the processing of fresh-cut vegetables, fruits,
poultry, and red meat [26–29] and the cooling water in canneries [30].

B. Critical Control Limits

Critical control limits are set to distinguish between safe and unsafe operating conditions
at a CCP and should not be confused with operational limits that are established for reasons
other than food safety. The commonly used control factors with critical limits for pro-
cessing water to meet are as follows:
1. Total bacterial count. Total bacterial count proved to be the most practical
and sensitive indicator of the removal and inactivation of microorganisms in
individual processes [31].
2. Total coliform bacteria. Coliform bacteria are used as indicators of microbial
contamination of drinking water because they are easily detected and found in
the digestive tract of warm-blooded animals. While not all of them are disease
producers, they are often found in association with other microbes that are capa-
ble of causing disease. Coliform bacteria are more tolerant to adverse environ-
ments than many disease-causing organisms; therefore, their absence from water
indicates bacteriological safety for human beings [31].
3. Fecal coliform (mostly E. coli). Fecal coliform constitutes a portion of the
coliform bacteria group. They are originated in the intestinal tract of warm-
blooded animals and passed into the environment in feces. Fecal coliform is
often used as an indicator of the fecal contamination of domestic water supply
[32].
4. Coagulase test. A positive response indicates that Staphylococcus aureus, Lis-
teria monocytogenes, Legionella spp., and some other related pathogens should
be taken into consideration.
5. Temperature. In many food processing operations the optimal temperature is
decided by more than one single factor. Besides the reduction of the risk of
microbial hazards, the maintenance of other quality attributes should also be
considered. Take the wash water temperature, for example. Rodriguez de Led-
esma et al. [33] used hot water (95°C) for the decontamination of poultry skin
and found a significant reduction in the microflora. However, cold water at 5°C,
instead of hot water, should be used to wash fresh-cut vegetables to optimize
the produce quality [27].
6. Antimicrobial chemicals. The effectiveness of antimicrobial agents depends
on their chemical and physical states, treatment conditions (water temperature,
acidity, and contact time), and the resistance of pathogens [34]. Chlorine, for
example, is commonly added to water to maintain a concentration of 50–200
ppm, at a pH of 6.0–7.5, with contact time of 1–2 min for post-harvest treat-
ments of fresh produce. Ozone has been used to sanitize wash and flume water
in packing house operations. Ultraviolet radiation may also be used to disinfect
processing water [26]. Chlorine dioxide, trisodium phosphate, and organic acids
© 2003 by Marcel Dekker, Inc.
 (such as lactic and acetic acids) have been studied for use as antimicrobial agents
in produce wash water [35]. Operators should investigate available options of
water sanitation and choose the most appropriate one for their individual opera-
tions.
7. pH. Adjusting the pH of processing water down to a certain level may be an
effective safeguard against many pathogens. However, when hypochlorites are
used as the antimicrobial agent, the reduction in pH may be offset by the in-
creased self-decomposition of these chemicals [36].
8. Contact time or flow rate. The effectiveness of a cleaning or cooling operation
is affected by contact time [37]. The flow rate of processing water is usually a
convenient measure of the contact time.
9. Pressure. When a pressure wash is used, critical control limits on the pressure
should be set and monitored.
Critical control limits must be based on scientific knowledge. It is not unusual to
implement more than one criterion of food safety at a single CCP.

C. Corrective Actions
When water quality deviates out of control limits, suitable corrective actions must be
undertaken in order to re-establish control as quickly as possible. These actions must be
planned in advance and should be able to determine and correct the cause of noncompli-
ance. The product produced during the period of the deviation must be held and tested
for acceptability for human consumption before it is released to the market.
Corrective actions for water quality deviation include adjusting pH, temperature,
flow rate, recycled water mixture ratio, and chlorine addition and may involve turning on
the backup water treatment system to keep the normal process operation uninterrupted.
When the deviation persists, discontinuation of the production is required for identification
of the possible causes. It is essential to record the whole event, including the actions taken
to correct the deviation, the identification of deviant lots, and the actions taken to ensure
the safety of these lots. These records must remain on file for a reasonable period after
the expiration date or expected shelf-life of the product.

D. Verifications
According to the Codex Alimentarius [38], verification of CCP is the application of meth-
ods, procedures, tests, and other evaluations, in addition to monitoring, to determine com-
pliance with the HACCP plan. The first phase of the process is the scientific or technical
verification to prove that critical limits at CCPs are satisfactory. The critical limits of
water quality are usually set by laws or regulations [39]. There is no need for factory
operators to verify the scientific basis of these limits. The second phase of verification is
to assure the effectiveness of the HACCP plan. The actions include evaluating the execu-
tion of water management procedure, reviewing the CCP records, and determining whether
appropriate risk management decisions and product dispositions are made when deviations
occur. Supervisors should be appointed to carry out periodical cross-checks among the
records of CCPs, disinfectant consumption, maintenance expenses, and utility bills to vali-
date the accuracy. The most recent sample report for the water analysis should be retained
on file in the food processing plant. The third phase of verification consists of revalidations,
independent auditing, and/or other procedures to ensure the performance of the HACCP
© 2003 by Marcel Dekker, Inc.
 plan. The water safety management plan should be discussed, and if necessary amended,
according to the frequency of water quality deviation, a shift in quantity and quality of
water supply and demand, and any changes of the HACCP plan that affect the water
supply mechanism of the food plant.

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