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July 11th, 2016

UV disinfection and FSMA – preventive control for source water protection

Dan Shaver, Aquionics Inc.

It’s no secret that water quality is extremely important to many food & beverage manufacturers around the world. However, when it comes to addressing product safety, is the absence of any past source water contamination issues considered a “good enough” strategy? Not according to the FDA’s Food Safety Modernization Act (FSMA).

Aside from following the guidance of the FDA under FSMA, the more practical question might be why a plant would spend crucial budget dollars to implement a protection strategy when there are other financial priorities to address. Many of these food & beverage plants would likely tell you that their product is safe because their municipal water is, and always has been, safe. But how do they really know? If they are basing this statement on the lack of historical contamination events, it’s likely that the FDA cares more about a facility’s preventive measures than they would about their historically clean track record of source water quality. Facilities that address the “what ifs” will be in a much better position in terms of product and brand protection, than facilities left to deal with potential operational issues and repercussions of a product recall linked to a contaminated source water event.

Putting aside the regulatory details, past contamination issues, or existing water treatment practices already in place, there is a simple question that every QA manager should be asking: “Is our plant equipped to effectively deal with a source water contamination event today, and if not, do we understand the potential risks associated with not considering a FSMA compliant strategy to protect our source water?”

There are a number of FSMA components that encourage facilities to look beyond historical records and existing water treatment processes to address some key regulatory check points and ensure there is adequate protection for the future. UV disinfection is able to address many of these criteria directly:

FSMA’s Component:UV Disinfection Feature:
Preventive ControlsUV acts as a firewall to protect all incoming source water from microbial contamination, usually as a compliment to existing RO, activated carbon or other filtration techniques.

ParametersUV can ensure a minimum dose (mJ/cm2) and log inactivation based on accurate sizing or 3rd party performance validation.

MonitoringUV controls can provide intensity (lamp) and transmittance (water quality) monitoring devices.

Corrective ActionUV can provide real-time power adjustment to compensate for operational variables (lamp/water) and ensure minimum performance.

VerificationUV systems display dose on the equipment as well as provide proof of 3rd party validation.

RecordkeepingUV is equipped with data logging capabilities for all essential performance and quality metrics.

More info on FSMA can be found here:
https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334115.htm



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