The Use of Water in Animal Production, Slaughter, and Processing
ADOPTED 22 APRIL 2021, WASHINGTON, DC
2018-2020 National Advisory Committee on Microbiological Criteria for Foods
Table of Contents
FSIS Charge: The Use of Water in Animal Slaughter and Processing........................................... 3
Background ................................................................................................................................. 3
Executive Summary .................................................................................................................... 3
Charge Questions to the Committee and Committee Responses.................................................... 4
Responses to Charge Question #1................................................................................................... 9
Water Conservation................................................................................................................... 10
Responses to Charge Question #2................................................................................................. 13
Factors that Determine the Choice of Technology.................................................................... 13
Animal Harvest and Raw Processing........................................................................................ 13
Ready-to-Eat and Further Processing........................................................................................ 14
Sanitation and Plant Design ...................................................................................................... 14
Existing New Technologies for Wastewater............................................................................. 15
Feasibility of A Fully Closed System ....................................................................................... 18
Establishment: Harmony Beef, Calgary Alberta Canada.......................................................... 19
Responses to Charge Question #3................................................................................................. 22
Nature of the Contaminants....................................................................................................... 23
Chemical Contaminants, Including Chemical Sanitizers.......................................................... 24
Biological Contaminants........................................................................................................... 26
Contaminants at Different Processing Steps ............................................................................. 27
Responses to Charge Question #4................................................................................................. 28
How Residual Contaminants Affect Product Quality and Safety ............................................. 28
Quality and Public Health Implications in Reconditioned Water............................................. 30
Assessing Quality Implications and Risks ................................................................................ 32
Effect of Residual Contaminants on Materials Added During Food Processing...................... 35
Responses to Charge Question #5................................................................................................. 36
Monitoring Quality and Safety of Alternatively Sourced Water .............................................. 36
Responses to Charge Question #6................................................................................................. 41
Pond Water................................................................................................................................ 41
Transport Water......................................................................................................................... 42
Processing Water....................................................................................................................... 42
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Responses to Charge Question #7................................................................................................. 44
Table 1-4. Modified audit grid of potential water conservation and savings opportunities in
Table 4-1. Summarized charge questions 4 and 5 for the committee translated into the risk
Table 8-2. Sanitization or disinfection products and devices with potential for decreasing
Figure 4-1. Example of a risk-based decision tree to match fit-for-purpose applications of
reuse water with either a food contact application or a not-for-food-contact application (from
Appendix #2. Sanitizers and disinfectants. Examples of measures of effectiveness required for
Responses to Charge Question #8................................................................................................. 49
Tables............................................................................................................................................ 53
Table 1-1. Estimated amount of water used during processing by species............................... 53
Table 1-2. Water usage in broiler processing............................................................................ 54
Table 1-3. Water usage in beef processing. Taken from Li et al. (2018), Pype et al. (2016) and
Warnecke et al. (2008)
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protein processing. .................................................................................................................... 56
assessment framework............................................................................................................... 58
Table 8-1. Cleaning mechanisms with potential for decreasing facility water use................... 59
facility water use. ...................................................................................................................... 60
Figures........................................................................................................................................... 61
FAO/WHO, 2019)..................................................................................................................... 61
Figure 7-1. Developing an Emergency Water Supply Plan (EWSP)........................................ 62
Appendices.................................................................................................................................... 63
Appendix #1. Critical water usage in animal growth and processing facilities ........................ 63
EPA registration for use on hard food contact surfaces. ........................................................... 64
Glossary ........................................................................................................................................ 65
References..................................................................................................................................... 69
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FSIS Charge: The Use of Water in Animal Slaughter and Processing
Background
Current FSIS regulations on the use of water during the processing of meat and poultry products
were last updated in the 1990s and may not account for the most recent technologies or
alternatives to water use. Water requirements for establishments slaughtering and processing
meat and poultry products are covered in the sanitation regulations in 9 CFR 416.2(g)(1), (2),
(3), (4), (5) and (6). The water used in food processing must comply with 40 CFR 141, the
National Primary Drinking Water regulations, if a municipal water supply is used. If a private
well is used, food processors must make documentation certifying the water’s potability
available to FSIS. Regulation 9 CFR 416.2(g)(4) limits the use of reconditioned water and may
not reflect current technological capabilities of water treatment. Climate change is challenging
the food industry’s access to clean and inexpensive water. The frequency, severity, duration, and
location of weather and climate phenomena (i.e., rising temperatures, flooding rains, and
droughts) are changing, which will continue to impact the food industry’s ability to produce safe
food. It is essential that regulatory agencies assess these changes and evaluate current regulatory
requirements associated with water use. They must also be able to provide alternatives to current
water consumption practices that allow industry to use less and recycle more water through
developing criteria on the appropriate uses of water sources in the processing of food.
Executive Summary
Water is an essential part of food animal processing, and current processing practices use large
volumes of water. Due to climate change, the food industry’s access to clean and inexpensive
water is increasingly a challenge. The Food Safety and Inspection Service (FSIS) seeks
evaluation by the National Advisory Committee on Microbiological Criteria for Food
(NACMCF) to facilitate the safe reuse of sources of water in order to reduce water consumption.
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Charge Questions to the Committee and Committee Responses
FSIS requests guidance from the NACMCF to address alternatives to current water usage
practices, guidelines, and regulations for FSIS-regulated products to help clarify the following
issues:
Charge Question #1
What are the current water usage practices for slaughterhouses and processors? At which steps
might water conservation or alternative water sources be feasible?
Summary/Recommendations
• There is a large variability, such as processing practices for each animal, practices within the
same animal species, etc., in the application of water in food-animal processing.
• There are a limited number of publications on water use by species. The industry may have
some information that is not publicly available.
• Important gaps are the lack of information for pork and channel catfish processing.
• Water management strategies should include water conservation practices, which are low-
cost practices that may result in important reductions in water usage.
• The 2020 COVID-19 pandemic may have a large impact on the increase of water usage,
specifically related to the implementation of more stringent cleaning and sanitation practices
in meat and poultry processing establishments.
• There should be more collaborations among stakeholders (e.g., industry, academia,
government) to collect missing information on water usage and opportunities for reuse.
Charge Question #2
What are the available technological strategies for water reuse, recycling, reconditioning, and
reclamation, and how might FSIS-regulated facilities employ them? Is a fully closed water
system reasonable as a goal?
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Summary/Recommendations
• Many factors influence the type of wastewater treatment methods that an establishment can
implement, including the local cost of water and the cost of the technology.
• There are already examples of water reuse in a counterflow direction to the movement of
product, such as the counterflow scalders and chillers used for the processing of chickens.
• Water conservation, based on judicious use of water changes in behavior, is an important
starting point to reduce the overall water usage.
• A complete understanding of energy use and plant infrastructure limitations is necessary to
effectively understand all opportunities for water conservation and recycling.
Charge Question #3
Water contaminants can be microbiological, chemical/toxicological, physical, and nutrient in
nature. Identify these contaminants and how their presence and concentrations in potable water
(municipal and well-sourced) compare to those found in water treated using the reuse, recycling,
reconditioning, and reclamation technologies identified in (2) above. Identify the risks posed by
these contaminants for various steps in food production and processing.
Summary/Recommendations
• Characterization of microbial and chemical contaminants in water is a very large topic that
requires extensive work.
• There are quality standards for potable water but not for the recycled water from different
processing states, and different water treatment systems.
• Different treatments may deal with different contaminants. Thus, a comparison of potable
water versus reused/recycle/reconditioned water is not easy to address.
• As we move to fit-for-purpose water recycling and usage, quality standards may need to be
developed for each application and recycling system.
Charge Question #4
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How do residual contaminants in water used for animal production, slaughter, and processing
affect product quality and safety? What are the quality implications and public health risks
associated with contaminants at levels anticipated for reconditioned water? How might FSIS and
industry best assess those implications and risks? How do residual contaminants in water affect
the functions of various materials added to water used in all stages of food production and
processing, such as feeds, medicines, and antimicrobials? For example, consider the effects of
trace pharmaceuticals on animal husbandry, and the effects of iron and “hard water” on
phosphate-based interventions.
Summary/Recommendations
• The distinction of two water quality standards, one for water that has direct or indirect
contact with food and one for water that has no contact with food, best assures safety.
• FSIS and industry can use a fit-for-purpose risk assessment approach to assess public health
risks from water reuse in food contact applications that do not already require potable water
quality and make the risk assessment adaptable to the specific food and use situations.
• Reused water in animal processing should be evaluated to ensure that the finished products
do not exhibit an increase (relative to current water usage practices) in the health risks
associated with these products.
• A uniform standard for, and federal regulation of, the quality of reused/recycled water in
FSIS-regulated facilities is needed. Currently, local authorities using highly variable criteria
determine both the water standard and regulation.
Charge Question #5
What are the best ways to assure and/or monitor the quality and safety of alternatively sourced
water used in FSIS-regulated operations?
Summary/Recommendations
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• There are physical, chemical, and microbiological parameters that have been traditionally
monitored to assess water quality.
• Standard water analysis methods are available, well-developed, and reliable. Initial
monitoring of alternatively sourced water should be extensive, while ongoing performance
monitoring should be in real-time and focus on measuring indicators (refer to Glossary).
Water for non-food contact uses will require monitoring of fewer parameters.
• The set of quality parameters to be tested, and the frequency, should be developed for each
technology and application based on the contaminants of concern and those that the
technology will reduce/remove.
• This set of quality parameters could include indicators of water quality for each food animal
species, for different areas in processing and for the processing areas where reprocessed
water will be used.
Charge Question #6
Are there special considerations for foods that are produced entirely within water (e.g., fish), and
if so, what are they?
Summary/Recommendations
• Maintaining good water condition in fishponds is essential to control fish diseases and to
provide adequate production of channel catfish.
• Some water conservation strategies have been published for fish processing establishments;
however, economic and other incentives to incorporate conservation practices or recycling
technologies do not exist.
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Charge Question #7
Flooding can contaminate animals and water sources with human sewage and farm waste. What
precautions should establishments take when floodwater or runoff affects a food or water source,
or a processing area?
Summary/Recommendations
• Companies should develop emergency programs to manage natural disasters, such as
flooding.
• There are several national and state guidelines that can be reviewed for the organization of
these emergency programs.
Charge Question #8
What technologies are appropriate for the replacement of liquid water in food production and
food processing areas (e.g., foam, mist, or dry chemicals)?
Summary/Recommendations
• Conducting a review of cleaning and sanitation and other manufacturing practices and the
use of alternative technologies, such as air chilling instead of water chilling, helps in the
identification of areas in which changes could contribute to an overall reduction of water use
in a processing establishment.
• Newer technologies (e.g., ozone generators and ultraviolet treatments, surface coatings with
sustained antimicrobial properties) are being approved by the EPA for specific sanitation
practices and may provide viable alternatives to reduce water usage during the cleaning and
sanitizing practices in animal food establishments.
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Responses to Charge Question #1
What are the current water usage practices for slaughterhouses and processors? At which
steps might water conservation or alternative water sources be feasible?
There is a large variability in the application of water in food animal processing. This variability
includes differences in the processing practices for each animal species (beef, pork, poultry and
channel catfish), and variations within the practices employed within the same animal species.
Other factors that affect water usage practices include the available and implemented
technologies at the establishments, the equipment and practices in place, education and training
on water conservation (refer to Glossary), and the actual cost-benefit of water
conservation/recycling/reuse (refer to Glossary) for each establishment. However, there is
limited information on the exact water use at each of the different processing steps, and for the
different food animal establishments in the USA (Compton et al., 2018; Meneses et al., 2017).
There is also limited information on the cost-benefit of each of the available water
conservation/recycling/reuse technologies.
In general, meat processing may account for up to 24% of freshwater consumption in the food
and beverage industries, while seafood accounts for approximately 2% (Bustillo-Lecompte and
Mehrvar, 2015). A report from Australia estimated that the water usage in beef slaughter
establishments varied from 3.8 to 17.9 kiloliters per ton of carcass weight produced (Warnecke et
al., 2008).
Table 1-1 describes the estimated amounts of water used during the processing of broiler
chicken, beef and turkeys. Although there are several reports on the use of water in
establishments processing broiler chickens and beef, there is less information about
establishments processing turkeys, pork and channel catfish. Most of the published studies about
water use in beef are from countries other than the USA.
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Water Conservation
The potential costs-benefits for water reuse or recycling projects may result in an increased
efficiency by the establishment, with energy savings and more efficient use of antimicrobial
applications. A complete understanding of energy cost and plant infrastructure limitations is
important to effectively understand all opportunities for water conservation and recycling.
The water usage in broiler processing is described in Table 1-2. Poultry harvest facilities rely
primarily on water to drop the temperature of the carcasses post-evisceration and to deliver
antimicrobials to control bacterial pathogens. For broiler chickens and turkeys, water chillers are
as large as 200,000 gallons. The major water usage occurs in the areas from evisceration to
carcass chilling. In each of these areas, there are opportunities for water conservation. In some
cases, the industry has reused water (refer to Glossary)from the end of the chill tanks to feed the
scalding tanks (Amorim et al., 2007; Blevins, 2020; Matsumura and Mierzwa, 2008; Northcutt
and Jones, 2004; Russell, 2013).
In a study conducted in a broiler processing plant in Brazil (Amorim et al., 2007) with a water
supply consisting of 99.5% deep water wells and 0.5% public water supply system, the proposals
for water consumption reduction included:
• Reusing effluent from cleaning of transport cages (after removing coarse solids) would
result in reductions of:
o 12% of drinking water consumed
o 1% of the effluent generated
• Reusing effluents generated by the cooling towers and in the de-freeze of cooling
tunnel/storage chambers; 7.5% and 1.4% of wastewater (refer to Glossary) generated,
respectively; to wash live poultry receiving and unloading yards would result in
reductions of:
o 91% of drinking water consumed
o 7% of the slaughterhouse's overall water consumption
o 9% of the effluent generated
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• Reusing effluent from the final rinsing of the slaughterhouse cleaning process to pre-
wash the by-product room would result in a 4% reduction in overall water consumption.
• Using all three of the proposals listed above would result in:
o A reduction of about 12% of the water taken from the deep water well
o A reduction of approximately 10% in the effluent generated
o A savings of approximately $6,500 (US) per year in wastewater treatment costs
These authors also highlighted that the incorporation of automatic, pressure-activated closing
water taps could save approximately 40% of water compared to conventional taps, and that
incorporating an infrared device for opening and closing of taps would save an additional 30% of
water usage (Amorim et al., 2007).
Table 1-3 describes the estimated water usage in a beef processing facility. A review from an
Australian beef processing facility highlights that water conservation can save up to 10% of the
water usage in a small town (Pype et al., 2016). Water reuse, which is described by these authors
as the “reuse of one process waste stream to the same or another process with or without pre-
treatment,” could save up to 15% of a town’s water usage. The publication also highlights that in
small towns, the recycling of non-potable water can save up to 40% of town water use, with a
recovery on the investment within 6 to10 years. The recycling of potable water (refer to
Glossary) can save up to 70% of town water use, with a recovery on the investment of about 10
years. The calculated payback time of implementing these practices ranged from immediate to up
to three years (Pype et al., 2016). Yet, some water reuse technologies may not be practical or
economically feasible for small slaughter establishments.
In pork and beef harvest establishments, carcasses are chilled primarily by air chilling. However,
water spray chill systems are also employed throughout the pork and beef industries. Because the
skin is not removed in the initial steps in pork processing, various methods of carcass scalding
are used to remove hair follicles and wash the carcass. This can be done via large scald tanks or
can be accomplished using other technologies, such as steam through vertical scalding units.
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There is no publicly available data on the use of water in channel catfish processing. There are
advantages in improving water management and there are several companies providing water
conservation consulting services to the food industry. Most of these companies collect
background information on water usage in an animal food processing establishment by
performing water audits, which can help create a water management plan to better understand the
total water consumption and discharge, and identify inefficient or unnecessary uses, such as taps
that are left on overnight. By applying a checklist of good practices, and systematically metering
and tracking the volume of water used in a facility, an establishment can help to identify areas
for potential water conservation (Timmermans, 2014). Table 1-4 shows the areas of a processing
environment where there is potential for conservation and savings.
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Responses to Charge Question #2
What are the available technological strategies for water reuse, recycling, reconditioning,
and reclamation, and how might FSIS-regulated facilities employ them? Is a fully closed
water system reasonable as a goal?
Factors that Determine the Choice of Technology
Water is a necessary component for meat production and meat processing. Water serves an
important role in product formulations, processing, sanitation, and food safety. However,
considerations for technology used for wastewater treatment methods and the ability to reuse
and/or recycle is plant- specific. These abilities are based upon the primary function and the
infrastructure of the plant, the efficiency and cost of implementing these strategies, and
regulatory requirements for both water end use and effluent.
Animal Harvest and Raw Processing
Water is vital in providing safe and wholesome food products of animal origin. The recognition
of food safety and the removal of pathogens during meat processing has required the use of
surface antimicrobials to be used throughout the harvest process. These surface antimicrobials
are often diluted processing aids that are effective against eliminating pathogens, but also have
the least organoleptic effect on the quality of the meat. The reliance and need for these surface
antimicrobials will continue as standards for food safety increase.
A few opportunities for water reuse present themselves in the harvest process across all animal
protein establishments. In general, water that is the cleanest and least contaminated should be
used after the evisceration process. However, considerations for water quality, as it relates to
food safety, will need to be evaluated to determine opportunities for reuse. An example of a
potential scheme for the utilization of reused water in a turkey harvest operation could be the use
of water in a counter-flow direction to the movement of product:
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Chiller Water Final Bird Wash First Bird Wash Feather Wash Cage wash
Larger scale capital projects would need to be evaluated on their merits and overall cost. An
example of water usage reduction would be a pork processing plant considering a change from
water spray chilling carcasses to utilization of a mechanical process of chilling, such as blast
chilling. Evaluation for the water usage from spray chilling would need to be assessed against the
increased overall energy usage from blast chilling to determine if there is a net environmental
benefit, an assessment for a potential opportunity to reuse the water used in a different
application further upstream in the process, as well as a financial net present value gain by
making the change.
Ready-to-Eat and Further Processing
The water usage in further processing facilities should also be considered. Like harvest and raw
processing facilities, water is used for sanitation, to deliver ingredients in formulation, and to
improve food safety. Many of the ingredients delivered with water are vital to the functionality,
identity, palatability, and safety of the product. Functional ingredients such as salt, sugar, sodium
nitrite, and antimicrobials are carried into the product via a brine. Thus, potable water is the
minimum standard of acceptance for use in formulations.
Sanitation and Plant Design
Wet cleaning (refer to Glossary) sanitation is also widely employed throughout the meat
processing industry. Reduction of water use may not be practical because of its importance in
cleaning and sanitizing processing lines. However, opportunities for water reuse water in a
counter flow direction from the movement of product could be employed. An example of this
would be using water from the final bird wash upstream in the process, such as in the feather
wash or cage wash in the trailers used to transport the live birds. Due to the nature of the
processes and the types of contaminants present, there are fewer opportunities for dry sanitation
in the meat processing establishments. Because meat is an excellent growth medium for many
bacteria (including pathogens), wet sanitation is also required to provide processing “breaks” in
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production and a sanitation schedule that reduces pathogens and spoilage bacteria. Cleaning and
sanitizing protocols also limit the extent of the compromised product, should the product become
contaminated with a known pathogen that results in a recall. Extended product runs to reduce the
frequency of sanitation are often product specific and need to be monitored and verified to show
effectiveness with respect to food safety requirements (Anonymous, 1999).
Besides water usage implications, there are other potential meat quality, food safety, and cost
implications that need to be considered if changes to water usage practices are considered. Many
of the processing plants in the USA were built before many environmental conservation practices
were envisioned and included within the building design. Thus, electrical, plumbing, and sewage
requirements may present cost barriers that are difficult to overcome. Also, the ability to utilize
reused and/or recycled water (refer to Glossary)may require space that may not be available in
older processing plants without major renovation or construction of the facility. Inline treatment
systems and the need for holding tanks may limit a plant’s ability to utilize reused or recycled
water in the current footprint of the plant.
Existing New Technologies for Wastewater
The US EPA has established Effluent Guidelines (US EPA, 2002) to comply with national
standards for industrial wastewater discharges to surface waters and publicly owned treatment
works (e.g., municipal sewage treatment plants). The Effluent Guidelines are issued for different
industrial sectors under Title III of the Clean Water Act. The standards are technology-based
(i.e., they are based on the performance of treatment and control technologies), and not risk-
based, or based on impact studies. The standards for wastewater discharges from meat and
poultry processing are codified under Title 40 of the Code of Federal Regulations (CFR) Part
432 (US EPA, 2002), and include the discharge limits for several parameters, or indices,
including pH, fecal coliform (refer to Glossary), total recoverable oil and grease, 5-day
biochemical oxygen demand (BOD
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; refer to Glossary), and total suspended solids. Some of
these indices provide information on the degree of organic pollution of the water.
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Bustillo-Lecompte and Mehrvar (2015) reviewed different slaughter wastewater treatment
methods. Following is a brief discussion of those different methods:
Land application: Land application refers to the direct application of biodegradable materials to
soil which can help increase the nutrient content of the soil. One significant advantage of this
process is the recovery of by-products from slaughter wastewater which can be used as an
alternative source of fertilizer. The land application process can also improve the structure of the
receiving soil. One limitation of land application is that the process is dependent on factors like
temperature and weather conditions. Hence, land application finds limited use in countries that
experience very low temperatures during the winter season. Some other limitations of land
application include potential surface water pollution, presence of persistent pathogens, and off-
odors (San Jose, 2004; Mittal, 2004; Avery et al., 2005; Kiepper, 2001).
Physicochemical treatment: In the process, slaughterhouse wastewater (SWW) is separated into
different components (primarily solids and liquids) using different types of methods (Al-Mutairi
et al., 2008; De Nardi et al., 2011): (a) dissolved air filtration (DAF), (b) coagulation and
flocculation, (c) electrocoagulation, and (d) membrane technology.
• DAF: These systems utilize air to separate liquids and solids in slaughter wastewater. The
separation of solids and liquids is achieved via introduction of air from the bottom of the
holding vessel. As a result, low density products like fat, grease, and light solids will migrate
to the top of the surface forming a “sludge blanket”. This sludge blanket will then
subsequently be removed. Advantages of this system results in improved chemical oxygen
demand (COD; refer to Glossary) and BOD. In addition, this system is also successful in
removal of nutrients from SWW. Some limitations noted by previous studies include a
regular malfunctioning of the system and poor total solids removal (Al-Mutairi et al., 2008;
De Nardi et al., 2011).
• Coagulation and flocculation: This process involves the addition of coagulants such as
aluminum sulfate, ferric chloride, or ferric sulfate to treat SWW. Studies showed that these
systems can significantly reduce the total phosphorous, total nitrogen and COD during SWW
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treatments using poly-aluminum chloride as reagents (Núnez et al., 1999; Aguilar et al.,
2002).
• Electrocoagulation: Electrocoagulation is a cost-effective technology that has been
demonstrated to be successful in separating solid and liquid waste in SWW systems. In
addition, the system was proven to be effective in removing organics, nutrients, heavy
metals, and even pathogens from SWW without the involvement of chemicals (Kobya et al.,
2006; Emamjomeh and Sivakumar, 2009)
• Membrane Technology: Membrane technology, which includes technologies such as
reverse osmosis, nanofiltration, ultrafiltration, and microfiltration, is very effective in
removing particulates, colloids, and macromolecules based on pore size. Some limitations of
this process include (a) a reliance on additional conventional technology to efficiently
remove nutrients; and (b) the potential to cause fouling due to the highly concentrated SWW
feeding streams (Bustillo-Lecompte and Mehrvar, 2015; Almandoz et al., 2015).
Biological treatment: Biological treatment involves treating SWW systems with
microorganisms for the purpose of removing organics. There are two main types of biological
treatments described in literature: anaerobic and aerobic systems (Bustillo-Lecompte and
Mehrvar, 2015; Martínez et al., 1995; Mittal, 2006; Masse and Masse, 2000).
• Anaerobic Treatment: It is commonly perceived that anaerobic systems are less complex to
operate compared to aerobic systems, since they do not require complex equipment and
constant aeration. Bacteria metabolize organic compounds and produce products like carbon
dioxide and methane during the anaerobic digestion process. There are several advantages to
using anaerobic treatment systems: high COD removal; low sludge production compared to
those of aerobic systems; and less energy requirements with potential nutrient and biogas.
One of the limitations of anaerobic treatment is it may produce effluents that do not comply
with current discharge limits and standards. Specifically, when SWW systems are subjected
to anaerobic treatments, stabilization of organic compounds may not be achieved owing to
the organic strength of SWW.
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• Aerobic treatment: In aerobic systems, bacteria metabolize organic compounds in the
presence of oxygen to facilitate removal of organic compounds. The strength of SWW
becomes a determining factor in understanding the amount of oxygen required during the
treatment of SWW systems. Typically, aerobic treatment is used following the treatment of
organic compounds using a physicochemical treatment. In other words, it may serve as a
final decontamination technology in the treatment of SWW. Aerobic reactors may have
several configurations based on the amount of nitrogen required to be removed. Typical
configurations for SWW aerobic treatment include activated sludge, rotating biological
contactors, and aerobic sequencing batch reactors (refer to Glossary).
Advanced oxidation processes (AOPs): AOPs are becoming an interesting alternative to
conventional treatment and a complementary treatment option, as either pretreatment or post-
treatment, to current biological processes. Furthermore, AOPs do not involve the application of
chemicals to inactivate microorganisms compared to the conventional systems (e.g., chlorination
that is used for water disinfection (refer to Glossary)may have the potential to produce hazardous
by products). As a result, AOPs have been recognized as processes that can offer advanced
degradation, water reuse, and pollution control, thus being positioned as an effective
complementary treatment. Several types of advanced oxidation process systems have been
described in the literature, including (but not limited to): ozonation, gamma radiation, and an
ultraviolet light/hydrogen peroxide application (Tabrizi and Mehrvar, 2004; Mehrvar and
Venhuis, 2005; Venhuis and Mehrvar, 2005; Mehrvar and Tabrizi, 2006; Bustillo-Lecompte and
Mehrvar, 2015).
Feasibility of A Fully Closed System
Establishments simply cannot operate without water. There are some system-wide reasons to
recycle water:
• Inherent energy cost: The cost of getting water out of the ground (or other sources), treat it
to potable standards, transport it to a facility, and then properly dispose of the wastewater by
treating to effluent standards and discharging back to the environment.
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• Competition for available water: As water becomes scarce, companies, especially those
located in proximity to or in metropolitan areas, will have to compete with municipalities.
• Social responsibilities: With increased attention to sustainability, the industry will want to
ensure that their water use is judicious.
Once companies consider all the above and other issues that may affect their access to water,
they will begin to recognize the significance of the business security that water recycling will
bring to their operation and realize the importance of this financial investment.
1. Obstacles to water recycling:
a. Outdated policies
b. Lack of national standards, with current regulations under the jurisdictions of states
and counties. Federal policies may be needed to increase consistency of water
recycling in all 50 states.
Establishment: Harmony Beef, Calgary Alberta Canada
Water Recycling System Manufacturer: Delco Water, Saskatoon, SK, S7P 0A6
(https://www.delco-water.com/delco-water-projects/harmony-beef/)
Storyline: A plant which was shut down for seven years was purchased, renovated and when the
time came to go on-line, the plant owners were told that their water allotment had been allocated
to a shopping mall. The owners had to find a solution and they focus on water recycling system.
After extensive world-wide search, they settle on a system designed and installed by Sapphire.
They are the first food processing plant in North America to reprocess their water. They recycle
all, except those of human waste stream, process water. Better than 90% of their daily water
needs are recycled water. The final discharge to sewer is only 7% of the process water volume,
with the rest lost to evaporation (Rich Vesta, Owner and Operator of Harmony Beef, Alberta,
Canada, Personal communications).
The process: They system is a continuous system with the flow rate of 13.9 L/second
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1. Mechanical Treatment: Water flows through drum screen with 1 mm slot openings to remove
coarse particles and large suspended solids.
2. Primary Treatment: inline analyzer to adjust the pH to 5.8-6.7 and then to Dissolved Air
Flotation (DAF; refer to Glossary) – This stage removes medium to fine size particles, grit,
fat, oil and grease. The removal is achieved by dissolving air in the water or wastewater
under pressure and then releasing the air at atmospheric pressure in a flotation tank basin.
The released air forms tiny bubbles which adhere to the suspended matter causing the
suspended matter to float to the surface of the water where it may then be removed by a
skimming device.
3. Secondary Treatment: Pumped to another tank for moving bed biofilm reactor (MBBR, refer
to Glossary), which is an attached growth biological treatment process. Prior to MBBR
inline analyzers adjust the pH to 6.8-7.2. It is an aerobic digester system
4. Tertiary Filtration: membrane ultrafiltration is used to remove emulsified oils, small,
suspended solids, and larger molecules from the flow.
5. Polishing: Water flows through dual Reverse Osmosis (RO) membrane to remove total
dissolved solids, pesticides, cysts, bacteria, and viruses. Utilizing a two-pass design
minimizes wastewater disposal from the treatment process.
6. Disinfection: U.V. filtration and then chlorinated to 1-2%
7. Pump to 500,000-gallon tank ready for use.
8. Sludge treatment – Finally, the sludge moves through a dewatering process to reduce sludge
volume by 60% to 70%.
Water Quality: Actual data from Certificate of Analysis (CoA) issued by Element (Calgary
Canada) for Harmony Beef. Examination of a number of such CoAs indicates very little
variability.
1. Microbial Analysis
a. Coliforms - <1.0 CFU/ml (below the detection limit of the method)
b. E. coli - <1.0 CFU/ml (below the detection limit of the method)
2. Physical and Aggregate: meets or exceeds standards
3. Chemistry
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a. pH 9.1
b. Electrical conductivity 392 microS/cm
c. Dissolved Calcium 1.1 mg/L
d. Dissolved Magnesium 0.3 ml/L
e. Dissolved Sodium 81.9 mg/L
f. Dissolved Potassium 5.8 mg/L
g. Dissolved Iron 0.01 mg/L
h. Dissolved Manganese 0.008 mg/L
i. Dissolved Chloride 37.6 mg/L
j. Fluoride <0.05 mg/L
k. Nitrate – N 0.03 mg/L
l. Nitrite - N 0.012 mg/L
m. Nitrate and Nitrite 0.04 mg/L
n. Dissolved Sulfate <0.9 mg/L
o. Hydroxide <5 mg/L
p. Carbonate 39 m/L
q. Bicarbonate 100 mg/L
Advantages:
1. No reliance on municipalities for water
2. No competition for human for water
3. Far better quality of water than municipal or well water
4. 3-4 years pay back
5. No need to lagoons
6. No incoming water or wastewater fees
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Responses to Charge Question #3
Water contaminants can be microbiological, chemical/toxicological, and nutrient in nature.
Identify these contaminants and how their presence and concentrations in potable water
(municipal and well-sourced) compare to those found in water treated using the reuse,
recycling, reconditioning, and reclamation technologies identified in (2) above. Identify the
risks posed by these contaminants for various steps in food production and processing.
This specific Charge question was found to be a large topic to cover, with extensive variations
due to the many different factors, including:
• Animal species processed
• Stage of processing at which water is used
• Contaminant under study
• Sensitivity of the methodology to detect the target contaminant
• System used to produce reused/recycled/reconditioned water (refer to Glossary)
There is limited information detailing all the potential contaminants (refer to Glossary), mainly
chemical and biological, that can be present in the water used during processing. Yet, it could be
assumed that all known contaminants of public health concern that have been identified by
species (e.g., Campylobacter spp. in broiler chickens, or Escherichia coli O157:H7 in beef)
could end up in processed water in an establishment processing that species. It is also important
to remember that water potability relates to drinking water standards and is done mainly by
testing for chemicals and coliform indicator bacteria, not by testing for pathogenic bacteria per
se.
Studies of drinking and recreational water have generated a large volume of information on risk-
based water quality thresholds for different water quality indicators using quantitative microbial
risk assessment (refer to Glossary). The presence of fecal indicator bacteria (FIB, fecal coliform
or enterococci) usually correlates with adverse health effects and are used as water quality
criteria in regulations aimed at protecting public health (US EPA, 2012a). Yet, human fecal
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indicator bacteria, not just all FIBs, are now accepted as the most important indicator of ambient
water contamination (Boehm and Soller, 2020). We do not have similar information on the most
appropriate indicators for water recycling in food animal processing establishments (refer to
answers for Charge Question #5).
Nature of the Contaminants
Water used in the processing of animal protein establishments contain high amounts of organic
matter, pathogenic and non-pathogenic microorganisms, residual chemicals from cleaning and
sanitizing activities (Bustillo-Lecompte and Mehrvar, 2015; Debik and Coskun, 2009; Masse and
Masse, 2000). An essential aspect of food safety efforts in meat, poultry, channel catfish and egg
products are the monitoring and control of chemical residues that may result from the use of
animal drugs and pesticides, or from incidents involving environmental contaminants. The
chemical contaminants coming with the live animal raised with proper husbandry practices
should not bring any public health concern. These contaminants include chemical compounds
added to the animal during production, such as growth promoters and antibiotics to control
animal disease.
There are specific regulations on the use and application of drugs in food production animals.
These regulations establish withdrawal times for chemical compounds that need time to clear up
from the animal and be at levels that do not represent human health concerns. The U.S.
Department of Agriculture’s Food Safety and Inspection Service (USDA FSIS) administers the
U.S. National Residue Program (NRP) for meat, poultry, and egg products. The NRP is an
interagency program designed to identify, prioritize, and analyze veterinary drugs, pesticides,
and environmental contaminants in meat, poultry, and egg products. FSIS partners with the Food
and Drug Administration (FDA) and the Environmental Protection Agency (EPA) as the primary
Federal agencies that manage the NRP. The FDA, under the Federal Food, Drug, and Cosmetic
Act (FFDCA), establishes tolerances for veterinary drugs and action levels for food additives and
environmental contaminants and reviews violative residues reported to FDA by USDA FSIS for
risk-based inspection and compliance follow-up. The EPA, under the FFDCA, the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the Toxic Substances Control Act,
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establishes tolerances for registered pesticides. Title 21 CFR includes tolerance levels established
by FDA, and Title 40 CFR includes tolerance levels established by EPA.
FSIS publishes NRP Data (traditionally known as the Red Book) each year to summarize the
results of testing meat, poultry, and egg products for chemical residues and contaminants of
public health concern. When testing for residues in food animal tissues, test results reported by
FSIS laboratories are compared to a quantitative acceptable level (i.e., tolerance or action level)
to verify that the meat, poultry, and egg products tested are safe and wholesome and do not
contain levels of a chemical that would render the product adulterated.
The NRP domestic sampling program is comprised of two correlated programs: the scheduled
sampling program and the inspector-generated sampling program. Under the inspector-generated
sampling plan, the number of samples screened and collected has remained the same (FY 2016 -
2019), at approximately 174,000 samples screened per year. The violation rate has remained
below 0.4% and has declined since 2016. The predominant violative residues in the samples
were antibiotics, mainly ceftiofur, penicillin, and sulfadimethoxine, which account for 30%,
23%, and 9.7% of total violative residues, respectively. Of the violations reported, 85% were
attributed to cattle; dairy cows accounted for 71%, and bob veal for 14%. In samples from swine
slaughter (market swine, sows, roaster swine, boar swine, and feral swine), there were only 8
violative samples, which represented 0.03% of the swine samples (USDA FSIS, 2019). The
drugs in violations are mainly antibiotics found at higher than allowable levels. Thus, unless we
consider the potential adverse reaction to an antibiotic (e.g., penicillin), these antibiotics are not
per se a direct human health hazard.
Chemical Contaminants, Including Chemical Sanitizers
There is a potential for chemicals for sanitation practices to contaminate water used in animal
food processing plants, but there is no information on the impact of the accumulation of these
residual chemical sanitizers (refer to Glossary), or their by-products, on the efficacy of the
recycling technologies. In addition, there is limited information on the cost to remove all
sanitizer from contaminated water in an animal food processing establishment. It is not clear if
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interaction among different chemical compounds may bring challenges with water recycling
systems. Thus, this is an area where more information is needed.
The chemical compounds used to control pathogens during the processing of food animals, and
that have contact with food, have all received approval by FDA as generally recognized as safe
(GRAS; refer to Glossary) or as a secondary direct food additive permitted in food for human
consumption (Anonymous, 1977), more specifically as an “antimicrobial agent” (refer to
Glossary). These antimicrobial agents are considered processing aids with temporary technical
effect in the treated food and are ordinarily removed or not present in the final food. Thus, any
residuals that may be carried over to the final product are not expected to have any effect on the
final product. Through the shared ingredient approval process by the two agencies, USDA FSIS
makes judgments on a case-by-case basis using FDA’s approval of a compound to determine
whether a substance is a processing aid, and can be used as an antimicrobial agent, or is an
ingredient of a food. While USDA FSIS determines the suitability and effectiveness for the
intended purpose of use, the Agency also ensures that the conditions of use do not result in an
adulterated product. Once the suitability and safety of a compound has been determined, the
substance is added to FSIS Directive 7120.1 (USDA FSIS 2021a). USDA FSIS also maintains a
list of Safe and Suitable Ingredients that is periodically updated (USDA FSIS 2021b). Although
there is no information on the residues of “antimicrobial agents” (GRAS or secondary direct food
additives) in processing water, the probability of any accumulation of these substances in their
active forms in water is low.
Under regulations codified as Title 9 CFR Part 416 Sanitation, establishments under the
jurisdiction of USDA FSIS are required to implement and monitor written Sanitation Standard
Operating Procedures (Sanitation SOPs) and maintain daily records to document the
implementation and monitoring of the Sanitation SOPs and any corrective action taken. Under 9
CFR 416.4, the regulations require that:
§416.4(c) Cleaning compounds, sanitizing agents, processing aids, and other chemicals
used by an establishment must be safe and effective under the conditions of use. Such
chemicals must be used, handled, and stored in a manner that will not adulterate product
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or create insanitary conditions. Documentation substantiating the safety of a chemical's
use in a food processing environment must be available to FSIS inspection program
employees for review.
Companies selling cleaning and sanitizing agents must sell only compounds that have been
approved for these activities and are registered as antimicrobial pesticides with EPA under
FIFRA.
Within the food commodities under USDA FSIS, processed eggs and Siluriforme fish are
considered allergens. Therefore, establishments that need to reduce these allergenic proteins
from surfaces to avoid cross-contact will also have to establish cleaning and sanitation protocols
that are specific for these circumstances.
Biological Contaminants
Biological contaminates are important contaminants present in water used in animal food
establishments. Yet, the large variation in the type and amount of contamination in an
establishment makes it difficult to include all the potential hazards. Factors such as the origin of
the biological hazard (human, animal, environment), the potential for survival, and the difficulty
for removal play a role in the degree of contamination of wastewater and therefore each animal
food establishment is unique. Testing for all potential biological hazards is not practical and the
collection of information with a structured quality assessment of the wastewater and recovered
water has been described as an important initial step before implementing reconditioning (refer
to Glossary) treatments (Meneses et al., 2017).
At the time this report is written, the world is undergoing the COVID-19 pandemic and many
food processing establishments are using more stringent cleaning and sanitation protocols and, in
some cases, are disinfecting surfaces to reduce the spread of SARS-CoV-2. Thus, processors
may be reducing microbial loads further than what is achieved by regular sanitizing procedures
due to COVID-19.
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Contaminants at Different Processing Steps
The transformation of live animal into human food varies from species to species, but it can be
assumed that all the processing steps during the dressing of animal carcasses, where water
contacts the carcasses, will have the potential to contaminate the water with, primarily, biological
and chemical hazards. Once carcasses are eviscerated, washed, and the temperatures lowered,
there will be less water contacting the carcasses. Yet, some water is used during cutup, deboning
or portioning and may contain species-specific microbiological hazards.
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Responses to Charge Question #4
How do residual contaminants in water used for animal production, slaughter, and
processing affect product quality and safety? What are the quality implications and public
health risks associated with contaminants at levels anticipated for reconditioned water?
How might FSIS and industry best assess those implications and risks? How do residual
contaminants in water affect the functions of various materials added to water used in all
stages of food production and processing, such as feeds, medicines, and antimicrobials? For
example, consider the effects of trace pharmaceuticals on animal husbandry, and the
effects of iron and “hard water” on phosphate-based interventions.
As shown in Table 4-1, Charge Question #4 and Charge Question #5 can be broadly framed
using a risk assessment framework per Codex Alimentarius guidelines (FAO/WHO, 2001).
How Residual Contaminants Affect Product Quality and Safety
Not all FSIS-regulated operations’ steps require the use of potable water. Wastewater from some
processes, with or without additional treatment, may meet the requirements of various, specific
reuse and can be safely recycled. For example, Miller et al. (1994) found that the use of
reconditioned and chlorinated water on swine carcasses during scalding, dehairing, and polishing
had no effect on the load of foodborne pathogens (including staphylococci, enteric streptococci,
Listeria monocytogenes, coliforms, and Aeromonas) on carcasses (Miller et al., 1994).
Water used in FSIS-regulated operations can be broadly categorized as those with direct contact,
indirect contact, or no contact (refer to Glossary) with product. The following gives definition
and examples of each:
Water with direct product contact: Water that directly contacts the product or surfaces that
come into direct contact with the product being processed include:
• Final rinsing of edible product that is not further processed;
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• Preparation of surfaces including hooks, tables, conveyors, etc., that would have direct
contact with meat products or meat packaging materials;
• Final rinsing of clean-in-place (CIP) systems or manual cleaning systems; and
• Direct addition of water as an ingredient in a manufactured meat product.
Water with indirect product contact: Water inside the meat processing environment that is not
in direct contact with the product or product contact surfaces include:
• Environmental sanitation of non-meat product contact surfaces inside the processing
environment, with consideration for the risk of contamination of unprotected meat
product contact surfaces by aerosols or transfer of water from the non-product contact
surfaces; and
• As a diluent for cleaning and sanitation chemicals used in Cleaning-In-Place (CIP; refer
to Glossary) systems or manual sanitation, excluding the final CIP water rinse.
Water with no product contact: Water with the lowest risk outside of the meat processing
environment include:
• Boilers and cooling towers, with consideration for the risk of aerosols and transfer of
water into the meat processing environments; and
• Washing of transport vehicles, with consideration for the risk of cross-contamination
from containers to product packaging and then to product.
Spreading non-potable water on food (i.e., direct contact) may make the food unsafe, as this
water may contain pathogens and chemicals. Current regulations and guidance to industry found
in 9 CFR 416.2(g) and USDA FSIS’s guidance for water, ice, and solution reuse in poultry
mandate that water must remain free of pathogenic organisms and fecal coliform organisms and
that other physical, chemical, and microbiological contaminates have been reduced to prevent
adulteration of product (Anonymous, 1999; USDA FSIS, 1999).
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Creating various grades of water quality is not practical. The distinction of two water qualities,
one that has direct or indirect contact with food and one that has no contact with food, can
simplify the implementation of water reconditioning (refer to Glossary) programs while assuring
safety. Currently, both the water standard and regulation of that standard is by local authorities
and is highly variable across the nation.
Quality and Public Health Implications in Reconditioned Water
The quality of alternatively sourced (se glossary) water with no direct contact with product, used
inside the processing plant, as well as alternatively sourced water with no product contact, used
outside of the processing plant, could be of a quality less than potable. Based on animal type, life
stage, method of raising, and amount of processing, reconditioned water may vary greatly from
plant to plant.
Temperature and turbidity (refer to Glossary) are the physical characteristics that impact safe
water usage. Water temperature affects microorganism viability, the solubility of oxygen, and
increases or decreases the toxicity of ammonia and other substances. Turbidity is a measure of
the fine sediment suspended in the water and has no inherent health effects, unless it indicates
inadequate filtration that may not have removed protozoa like Cryptosporidium or Giardia
lamblia and/or infectious viruses or bacteria. Turbidity can also interfere with disinfection and
may include substances that allow microbial growth.
The chemical characteristics that impact safe water usage include pH, nutrients, ammonia, and
dissolved oxygen and metals. Chemical water properties are often interrelated. The pH describes
the balance between hydrogen and hydroxide ions that can affect many other chemical
constituents such as the dominant form of ammonia and the solubility of metals. Water acidity or
alkalinity can cause corrosion (both low and high pH) or precipitation and fouling (high pH).
Reused water may have extreme pH values from caustic washes or regeneration of ion exchange
resins. Nutrient levels are usually measured as nitrate-nitrite nitrogen and total phosphorus, but
can be as total inorganic nitrogen, organic nitrogen, or soluble reactive phosphorus. Ammonia is
naturally occurring in water but can increase when nitrogen-containing organic waste and
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dissolved oxygen levels increase. Dissolved metals can include arsenic, lead, mercury, iron,
cadmium, copper, sodium, chloride, potassium, manganese, or magnesium. Ingestion and
bioaccumulation in tissues can be a health risk for those who consume some metals. Mercury is
usually in inorganic form but can convert to toxic methylmercury in conditions of low pH, low
dissolved oxygen, and high dissolved organic matter.
Processing water may include the presence of residual sanitizing compounds, and their by-
products, used during processing. Results from the National Residue Program, described in
answers to Charge Question #3, highlight that agriculture and veterinary residues may not be a
public health concern in live animals that will be processed, if the application of agrochemicals
and the use of veterinary drugs follow appropriate guidelines for use. Please refer to the National
Residue Program under responses for Charge Question #3.
The microbiological properties that impact safe water use include pathogenic protozoa, bacteria,
and viruses. Organisms of concern include, but are not limited to, Campylobacter jejuni,
pathogenic Escherichia coli, Salmonella (including antimicrobial resistant strains of these
pathogenic bacteria), Cryptosporidium, spores of bacterial pathogens, Toxoplasma gondii,
norovirus, and helminths. Indicator organisms are often used as a marker or estimate of
contamination levels due to cost or inability to monitor the actual pathogen. The biological
indicators that highlight the potential of public health risk include the presence of fecal
coliforms, generic E. coli, and enterococci. In the case of parasites, such as Cryptosporidium and
Giardia lamblia, and viruses such as enteric viruses, the direct testing for the pathogen is used,
although some recent research suggest that bacteriophages can be used as indicators of fecal
pollution and enteric virus removal in recreational water (McMinn et al., 2017).
Australia has previously developed a national guidance document for water recycling which
covers both potable and non-potable end uses. The guidance document requires the development
of a risk assessment process for the “hazards getting through the treatment system in sufficient
amounts to pose a risk to human health” (Anonymous, 2008). In this document, six pathogens
from 52 airborne and waterborne pathogens from water reuse were identified as the pathogens of
concerns to address when recycling water, and some recommendations on how to ensure that the
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risk assessment process, based on examining reference contaminants to represent functional
groups of pathogens or chemical contaminants, is compatible with the Australian Recycled
Water Guidelines was provided by Warnecke et al. (2008).
Facilities currently engaging in water reconditioning and reuse are reusing cleaner water for
areas where there are more contaminants and use only potable water for direct food contact.
Non-potable water is not allowed as an ingredient or to have direct contact with meat in the US.
Most European nations do not allow the use of recycled water in direct contact with meat (Pype
et al., 2016). Guidelines from the World Health Organization (WHO 2011) also highlight that
water from alternate sources that has direct or indirect contact with product must meet drinking
water guidelines. These types of regulations and guidelines have direct implications for the
international meat trade.
The risk of introducing hazards from the reuse of water in operations can be mitigated by
employing appropriate control measures, including engineering controls (e.g., filtering water on-
site), administrative controls (e.g., changing job tasks so one individual is not continually
exposed or showering out), and personal protective equipment (PPE) (e.g., gloves, mask,
protective eyewear, and coveralls). A risk assessment should be completed when there is a
change in systems, animal inputs, or water source or if there is the emergence of a previously
unidentified hazard. No water reuse system should be allowed to be put in place if it results in an
increased risk to human health. Therefore, while there are potential increased hazards with water
reuse, no increased risk to public health would occur with proper controls. Each plant will face
its own needs and challenges. Using technology coupled with well-trained individuals to
implement and monitor systems may protect public health while reducing environmental impacts
from water use in meat slaughter and processing.
Assessing Quality Implications and Risks
A report by the Food and Agricultural Organization of the United Nations (FAO) and the World
Health Organization (WHO) addressed the safety and quality of water used in food production
and processing (FAO/WHO, 2019). Although this report does not focus on water reuse, its
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principles are relevant to the question addressed here. The report highlights that water quality
should be established in a “fit-for-purpose” basis, considering the application and context, rather
than using the same water quality standards across all applications. In this report, authors
propose the use of decision support system tools which incorporate risk assessments and the use
of monitoring to inform stakeholders when making decisions on water quality and reuse at steps
in the supply chain (FAO/WHO, 2019). A challenge in the use of risk assessments is that
monitoring of water quality is often based on microbial indicators, which do not correlate with
the presence or quantity of pathogens in water or food. This means that continuous monitoring
might have to also include relevant pathogens, depending on the target application of the reused
water.
The report also highlights the similarities in risk management approaches in safe potable water
and safe food, such as that both are risk- and evidence-based and need proper verification and
monitoring. It also points out the additional complexities in food production due to the wide
range of products, primary production and processing systems, microbial hazards along the food
supply chain, and the end use of food products. As a result, the report recommends a risk-based
approach to water use and reuse instead of defaulting to specifying the use of potable water or
other water quality types (FAO/WHO, 2019).
As described earlier, different applications of reused water require different water quality
standards. For food contact applications, there are specific US regulations and WHO guidelines
on the need to have equivalence to potable water to prevent adulteration of food products with
biological hazards (Anonymous, 1999; WHO, 2017). The equivalence to potable water should be
based on quality indicators, and therefore risk assessment methodologies should incorporate
these quality indicators when evaluating the safety of reused water.
Assessing public health risks of an intervention requires quantifying the risk in absolute (i.e.,
total public health impact) or comparative (i.e., increase/decrease in public health risks from
status-quo) terms. For example, assessing the risks from a regulated animal product new to the
market would require estimating the absolute public health impact of that product, whereas
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knowing if a new regulatory intervention effectively reduces foodborne illnesses would require a
comparison of illnesses against current interventions.
Although potable water is safe, food products generated with potable water can still have certain
public health risks due to pathogen contamination throughout the production chain. Thus, reused
water for use in animal processing should be evaluated to ensure that its use does not result in a
net increase (i.e., relative to current water usage practices) in the number of human illnesses,
hospitalizations, and deaths attributable to animal products under USDA FSIS regulations.
Answering the question of reused water would be amenable to a comparative risk assessment
framework.
Regulatory risk assessments applied to food safety risk assessment were published, and should
follow Codex guidelines, chiefly Principles and Guidelines for the Conduct of Microbiological
Risk Assessment (CXG 30-1999) (FAO/WHO, 2001) and Working Principles for Risk Analysis
for Food Safety for Application by Governments (CXG 62-2007) (FAO, 2007). These guidelines
describe the main components of a risk assessment as hazard identification (identify food safety
hazard(s) from the intervention), exposure assessment (estimating the extent of anticipated
human exposure to the hazard as a result of the intervention), hazard characterization (estimating
the severity and duration of negative health outcomes resulting from exposure to the hazard), and
risk characterization (obtain a population-level estimate of the public health risks resulting from
the intervention). In the US, the USDA FSIS and the US EPA have published the Microbial Risk
Assessment guideline (US EPA, 2012b) for pathogenic organisms in food and water to achieve a
more consistent approach to microbial risk assessment across federal agencies. Such efforts have
resulted in an emphasis by US agencies regulating food on performing these fit-for-purpose risk
assessments, rather than following formulaic or overly strict risk assessment frameworks
(Dearfield et al., 2014). USDA FSIS also published a repository of current and past quantitative
risk assessments performed since the late 1990s in a variety of inspected products, mostly
concerning microbial contaminants (USDA FSIS, 2020a). Likewise, the US FDA makes
available to the public a variety of risk assessments and risk assessment resources for microbial
and chemical hazards (FDA, 2020).
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Based on the principle of fit-for-purpose risk assessment, FSIS and the industry should assess the
public health risks using a risk assessment approach for water reuse in food contact applications
that do not already require potable water quality. The risk assessment models should be
adaptable to the specific food and processing situations. The diversity in the different water use
scenarios and food products makes it difficult to recommend any specific risk assessment
framework (e.g., qualitative versus quantitative microbial risk assessment), but it should be
useful to create a series of use cases to provide examples and guidance of possible risk
assessments to apply in FSIS inspected products.
As proposed by the FAO-WHO (2019), following a risk assessment, a decision tree could be
used to assist industry in deciding the fit-for-purpose of water reuse under four different
applications (i.e., as food ingredient, intentional food contact, unintentional food contact, not for
food contact) and conditioning scenarios. An example of a relevant decision tree is provided in
Figure 4-1. Thus, the risk assessment and decision trees framework should be flexible enough to
accommodate such diversity.
Effect of Residual Contaminants on Materials Added During Food Processing
Residual contaminants (refer to Glossary), as indicated by high turbidity in non-potable, recycled
water may inhibit the ability of antimicrobials added to the water to reduce pathogens in water or
food. Turbidity can interfere with disinfection and may include substances that allow microbial
growth (Chahal et al., 2016). Thus, highly turbid/contaminated water should not be used in the
facility before further processing (see responses to Charge Question #2).
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Responses to Charge Question #5
What are the best ways to assure and/or monitor the quality and safety of alternatively
sourced water used in FSIS-regulated operations?
The safe use of reconditioned water requires monitoring to validate the initial processes and
ongoing verification so that water quality is consistent. The water source characterization and its
intended reuse will direct the allowable levels of substances. Initial monitoring of alternatively
sourced water should be extensive and may involve independent, accredited laboratories, while
ongoing performance monitoring should be in real-time and can focus on measuring indicators
rather than a complete analysis.
Source water (refer to Glossary) assessments consider a range of possible contaminants and can
be derived from lists such as the Guidelines for Drinking-Water Quality by (WHO, 2017) and the
WHO guidelines on the management of chemical contaminants (WHO, 2007). After the source
vulnerability assessment, it is not necessary to continually assess all potential contaminants and
analyses can focus on the relevant contaminants. The specific physical, chemical, and
microbiological parameters to be monitored, the frequency of monitoring, and on-line versus
discrete analyses should be chosen based on the distinct contamination vulnerability of the
source water.
Monitoring Quality and Safety of Alternatively Sourced Water
Effective methods to monitor and ensure water quality and safety are in use by municipal
wastewater treatment plants. Removal of nutrients and pathogens has been the focus of these
facilities for over 100 years. The same methods can be used for alternatively sourced water.
Typical wastewater treatment is monitored (using indicators) for the elimination of all
pathogenic microorganisms, except for spores.
Monitoring parameters for recycled water include investigative, process performance, and
verification. Initially, an investigative, comprehensive assessment of water contaminants in the
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source water should be done, as they may impact recycling. Annual water analysis should
document the overall quality of the incoming water and meet the regulatory requirements.
Standard water analysis methods are available, well-developed, and reliable (APHA, 2005). The
potential contamination in waters is evaluated by testing different parameters, such as pH, total
dissolved solids, total organic carbon (TOC), ammonia nitrite, nitrate, hydrogen sulfide,
dissolved oxygen, chloride, chlorine, sodium, sulphate, turbidity, urea, etc. TOC is an excellent
indicator of the treatment process performance and there are manual and in-line monitors
systems for rapid and inexpensive TOC evaluation. Total dissolved solids can be detected by
electrical conductivity, a measurement that provides information on dissolved inorganic ions in
water.
The presence of potential human pathogens is evaluated by testing for bacterial indicators, such
as aerobic plate counts (counts of total bacteria), coliforms, Escherichia coli, etc. Depending on
the incoming source, an initial analysis for lipid, protein, lactose/sugar, and minerals may be
needed to be sure the water quality will not adversely affect product or process. After the water is
used in processing, other tests should be considered, such as testing for residues of sanitizers or
the accumulation of metal cation. The type of parameters to monitor, and the frequency, will also
depend on whether the water is used directly on foods or food contact surfaces versus the use on
non-food contact surfaces.
The physical parameters of water include turbidity, which is an important indicator of microbial
quality (bacteria, parasites, viruses). In-line turbidity meters with alarm systems are available at
relatively low cost. Depending on the intended water use, real-time monitoring of turbidity is
recommended, and standard acceptable levels have been set (US EPA, 2018a).
The chemical parameters of water coming into the facility from outside should be known. There
should be an initial testing when a new source of water is used. Once the composition of the
source water is known and the treatment process is in place, the chemical composition does not
need frequent monitoring. There are numerous chemical indicators used to characterize the
quality of the water, such as specific metals (e.g., Fe, Mn, Pb), radionuclides (e.g., radium
226/228 and uranium in particular), anions (e.g., SO4, NO3-), silica, nutrients (e.g., NH3-,
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phosphorus oxyanions), and some specific synthetic organics. Color is generally an indicator of
organics in the water and is readily measured by visual or spectrophotometric methods. Odor is
important and can be checked by smell for objectionable aromas of sulfide or algal products.
Disinfectant residuals such as chlorine, chlorine dioxide, or chloramine residuals could be
detrimental for some products. Ozone dissipates rapidly and ultraviolet light provides immediate
disinfection with no residual. One or more disinfectants are required as part of the treatment
process to ensure microbial safety. Additionally, routine residual measurements are important to
establish presence and/or absence of residuals. Inexpensive disinfectant residual test kits are
available. However, in-line monitors for chlorine and ozone are preferred for continual
monitoring of microbial safety.
The microbial parameters of water should be monitored frequently because contamination risks
are acute. Reclaimed water (refer to Glossary) used in direct or indirect contact with product
should receive secondary treatment with disinfection. Also, for non-contact water reuse
identification of potential fecal contamination is an issue for worker safety.
Safety indicators can include monitoring filtration, disinfection, and the presence of residual
disinfectants. In general, and for different types of waters (e.g., drinking, recreational, animal
processing, etc.), microbiological water testing detects indicator organisms, instead of specific
pathogens, as a sign of fecal contamination. However, it is important to emphasize that many
microbial indicators (e.g., coliforms, E. coli, enterococci) have been used to assess fecal
pollution, but there is no direct correlation between the numbers of any microbial indicator in
water and the presence of an enteric pathogen (Grabow, 1996, Ashbolt, et al., 2001).
Heterotrophic plate count (refer to Glossary) estimates the number of live heterotrophic
microorganisms in water and provides some information about water quality. Yet, the test itself
does not specify the organisms that are detected and results in a wide range of quantitative and
qualitative results (WHO, 2001). Total coliforms are another bacterial group that can indicate
potential contamination, but coliforms can originate from many sources and are not good
sanitary waste indicators. Another group are the FIB (see response to answers for Charge
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Question #3), which have been used by public health agencies for several decades to identify
potential for illness resulting from recreational activities in surface waters contaminated by fecal
pollution (US EPA, 2012c).
The US EPA recommends the use of FIB, specifically enterococci and E. coli, as indicators of
fecal contamination for fresh water, and enterococci as indicators of fecal contamination for
marine water (US EPA, 2012c; 2012d). FIBs are considered “pathogen indicators” (refer to
Glossary), but the Agency recognizes that these microbial groups are not used as direct
indicators of pathogens by the scientific community (US EPA, 2012c). In addition, the Agency
has not yet published any criteria for pathogens per se (US EPA, 2012c).
Historically, Escherichia coli was considered an appropriate indicator organism for determining
the potential presence of bacterial fecal pathogens in reused wastewater. However, contemporary
research highlights that Escherichia coli may not be an effective indicator of water quality
because it appears and grows in natural environments in addition to the intestines of warm-
blooded animals (Whitman and Nevers, 2003). The large diversity within Escherichia coli
strains, and the actual sources of the majority of the Escherichia coli strains isolated from the
environment may not be identified by a library-dependent method (refer to Glossary) (Ishii et al.
2007; Jang et al., 2017). The use of other indicators, such as bacteriophages (McMinn et al.,
2017), to assess fecal pollution and enteric virus removal in recreational water also brings
uncertainties and have limitations for the modeling of microbial populations in recreational
water. Thus, we do not know the most appropriate indicators for each food animal species that is
processed. However, as our knowledge in this area increases, we expect to find other
microorganisms, or DNA markers, that could be used to assess the level of pollution in waters.
Microbiome sequencing has been suggested as the next method to help evaluate the efficacy of
cleaning and sanitation practices, antimicrobial intervention, and to provide information on the
quality of recycled water in animal processing establishments (Blevins et al., 2017; Feye et al.,
2020). Microbiome mapping using DNA data from next generation sequencing may help
processors understand the key microbes on the food product and in the processing water.
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There are real-time, in-line monitors systems to evaluate physicochemical properties quality of
recycled water. In-line monitors are available for pH, conductivity, turbidity, particle counts,
TOC, and many individual chemicals. In-line electrical conductivity monitors are inexpensive
and provide information on salinity, while in-line pH systems are simple and cost-effective.
Other in-line monitoring systems are expensive and require regular calibration, maintenance,
and trained personnel. There are no real-time, in-line monitoring systems to detect and count
microorganisms yet. However, signals from in-line chlorine and turbidity tests could in the future
be used to assess the level of microbial contamination in water.
Verification monitoring is needed when a system does not meet specifications and corrective
action is implemented. This monitoring assures performance and requires an increased frequency
until specifications for the specific parameter are consistently met. This is critical if the recycled
water has any product contact potential.
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Responses to Charge Question #6
Are there special considerations for foods that are produced entirely within water (e.g.,
fish), and if so, what are they?
The answers to this specific question focus on the growing, transporting, and processing of
channel catfish (Siluriforme fish).
Pond Water
Channel catfish (Siluriforme) are raised primarily in ponds in the southern states of Mississippi,
Alabama, Arkansas, and Texas, accounting for 95% of annual US sales of channel catfish.
Channel catfish production was valued at $380 million in 2018 in the US (NASS, 2019) and over
90% of the commercial channel catfish is produced in embankment/levee type of ponds, which
keeps the water free of pollutants and other species of fish. These water impoundments are
constructed on flat land where the dirt has been moved into a levee around the pond bottom and
usually range from 8 to 25 acres with a depth of 4 to 6 feet (Anonymous, 2020). Another system
of channel catfish production is the split-cell pond, where a traditional pond is split in half with
an earthen dam. This system is more efficient and may increase the production per acre
compared to embankment/levee type of ponds, but it requires much more intensive aeration
management due to the increased stocking rate (Coblentz, 2017).
The ponds in which channel catfish are produced must yield fish that are healthy and wholesome
for human food consumption. Ponds are typically filled with non-treated water from a ground
well. This water is used throughout the fish growing period and is replenished as needed. Water
conservation measures have been implemented to maximize capture of rainwater and at the same
time prevent ponds from overflowing and losing water during heavy rains (Tucker et al., 2016;
Tucker et al., 2017). Some ponds are drained and refilled annually; however, most ponds are
often used for up to 10 years without draining.
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Maintaining good water condition is essential to control fish diseases and to provide adequate
production of channel catfish. As with all food animal production systems open to the
environment, fishponds could potentially become exposed to foodborne pathogens from other
animals (wild and domestic) that have access to the area, but it does not appear to impact the
success in raising wholesome channel catfish (USDA FSIS, 2017). Because the water is used all
year and replenished as needed, there is no economic, or other types of incentives, for water
conservation/recycling, although some conservation practices have already been described
(Tucker et al., 2017).
Producers monitor pond water for production-related parameters (e.g., dissolved oxygen,
temperature, pH, alkalinity, hardness, total ammonia nitrogen, etc.), while USDA FSIS is
responsible for monitoring ponds for environmental chemicals and pesticides that can impact
food safety (USDA FSIS, 2017).
Transport Water
Catfish are harvested from ponds and transported to the processing establishments in live-haul
trucks that contain aerated water-filled tanks. The water in transport tanks may be sourced from
well water or the production pond. Wynne and Worts (2011) recommended that the transport
truck be scrubbed using a detergent, followed by a disinfection spray and then rinsed. It is
unclear if this recommendation is regularly followed in the industry. If trucks are used for
multiple runs from the same pond, disinfecting after every load may not be practical. Cleaning
and disinfecting trucks is a biosecurity measure to control the spread of diseases between fish
rather than a sanitation measure associated with food processing. Reduction of water use in
catfish transportation appears to be unlikely due to the concern with preventing transport stress
and disease transmission between loads.
Processing Water
Channel catfish processing comes under the jurisdiction of the USDA FSIS; therefore, Sanitation
Performances Standards and Standard Operating Procedures apply to water use and water supply
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as mandated by 9 CFR 416.2(g) (Anonymous, 1999; USDA FSIS 1999). These requirements are
adequate for channel catfish processing. As with other food animal processing, there may exist
possible water reclamation and reuse opportunities if the wholesomeness of the product is not
compromised.
Guimarães et al. (2018) evaluated the possible reuse of water in seafood processing in Brazil.
These authors evaluated industrial water management and quantified and qualified effluents from
general processing activities and concluded that direct reuse of processing water would not be
recommended due to the high number of bacterial contaminants. However, the authors also
concluded that indirect recycling of water from freezing tunnel and cooling chamber defrosting
could be used to supply cooling tower demands after a simple treatment and disinfection process.
It was estimated that this practice might reduce total average water consumption of the
processing unit by 11%. It was also noted that if effluents from cooling tower purges were also
reused, water reduction levels of approximately 22% could be attained.
Similar to the high number of bacterial contaminants described by Guimarães et al. (2018), other
food industries (e.g., beef processing and poultry processing) that have implemented processes to
capture, treat and reuse water, have also reported high levels of bacterial contaminants in the
water captured for recycling (Casani et al., 2005). However, various treatments have been proven
to be effective at bringing the water back to potable standards in order to be reused (Casani et al.,
2005). Although technologies for the recycling of water in food manufacturing exist, which
could also be useful in recycling water in the fish industry, these technologies would have to be
economically beneficial for the processing facility to implement.
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Responses to Charge Question #7
Flooding can contaminate animals and water sources with human sewage and farm waste.
What precautions should establishments take when floodwater or runoff affects a food or
water source, or a processing area?
Flooding events are considered “significant incidents” by USDA FSIS, meaning they represent
grave or potentially grave threats to people or products. These events could trigger a “Significant
Incident Response” by the Agency (USDA FSIS 2018). Depending on the scope of the
emergency, such an event could trigger response actions under the National Response
Framework, National Response Plan, and State emergency management activities (USDA FSIS
2019). The USDA FSIS “Significant Incident Preparedness and Response” program is a resource
for education, collaboration and assistance with preparing emergency response plans (USDA
FSIS 2020b).
Food production companies should have documentation for managing natural disasters, such as
flooding in a facility, that clearly define preparedness and response actions. This documentation
may be a corporate-level document that outlines general action items for establishments, and/or
establishment-level contingency plans or emergency response plans. These documents will give
direction on how to manage such situations, and typically include checklists that provide
guidance. General guidance on flooding preparedness is available for processing facilities,
including small and very small facilities, at the USDA FSIS website (USDA FSIS, 2013).
Companies also need to consider following state guidelines (e.g., Emergency Action Planning
Guidance for Food Production Facilities by the New Jersey Department of Health) (Anonymous,
2012).
A documented flood emergency response plan can give a facility’s staff a step-by-step course of
action to follow in times of need and help minimize losses for a business. Time invested in
training and educating staff members for natural disasters will help to keep team members and
animals safe.
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Industry-driven audits of food safety systems require facilities to have procedures designed to
effectively manage and report incidents and potential emergency situations that impact food
safety, quality or legality, including appropriate contingency plans. Incidents such as fire, flood,
natural disaster, malicious contamination or sabotage, digital cyber-security, etc., may include
disruption to key services such as water, energy, transport, refrigeration processes, staff
availability and communication. Facility operators should consider whether products from the
site may be affected by an incident before releasing them to market.
Floods or other natural disasters affecting an animal production facility need an immediate and
humane response to find, assess and secure the affected animals, consistent with the provisions
of the Animal Welfare Act (USDA APHIS, 2020), and with worker safety. If animals are present
in a facility during a flooding event, facility managers should follow established and applicable
Animal Welfare Policies to remove animals to a safe and secure area (USDA FSIS, 2011, 2015),
which include moving animals to safe locations, rinsing them down if heavily soiled, managing
and containing animal waste and contaminated water in accordance with applicable regulations,
rinsing down and cleaning all surfaces, sanitizing animal contact surfaces with approved
products, and forced air drying to prevent mold growth.
Following a flooding event in which flood water has entered an animal or processing facility,
managers should follow the SOPs in their emergency response plan to mitigate facility
contamination and damage in order to return the facility to a safe operational state. Large
debris/gross contamination can be removed from surfaces by removing them with clean water.
Fans or other mechanical drying equipment can be used to dry wetted surfaces more quickly to
reduce potential molding. Surfaces that have been contaminated by floodwater should be cleaned
with an approved cleaning product appropriate to the setting and operational process. If these
surfaces come in contact with animals or animal products, they should be sanitized with an EPA-
registered sanitizer.
A facility’s emergency response plan should also take into consideration potential damage to,
and contamination of, the facility’s water supply and distribution system. Whether for worker or
animal health, maintaining facility operations, or product quality, a safe water supply is a critical
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resource that needs to be incorporated into emergency preparedness and mitigation plans for
animal growing and processing (Appendix #1). Water-related emergency preparedness at a
facility includes understanding the water supply and how water is used in the facility. Flood
water can contain pathogens, chemicals and toxins that can contaminate a facility’s water supply
at its source, during treatment, or during distribution. If mitigation or preventive measures are
not taken, this contaminated water may be consumed by workers or used for facility production
processes like animal care and facility cleaning. Clean, safe water is essential for human and
animal consumption, proper hygiene, surface cleaning, and handwashing. It is important for
facilities to ensure their water supply is safe for intended purposes (Appendix #1).
If a facility is served by a municipal water system that experiences flooding, managers should
check with the local water authority to determine if a drinking water advisory has been issued,
and any precautions that should be considered (CDC, 2020). Many water utilities also offer text-
based alert systems for rapidly notifying customers of any drinking water advisories. State health
departments may also have guidance on emergency planning for water advisories and
interruption of water service (Anonymous, 2012). If the facility uses a groundwater well,
managers may consider consulting a well or pump contractor to have the well inspected to
determine if it or associated equipment has been damaged during flooding or is not working
properly. If managers suspect that a facility’s groundwater source might have been contaminated
by floodwater, they can contact their local or state health department or agriculture extension
office for advice on disinfecting the well (CDC, 2016). Before resuming use for drinking or
production, the well should be tested for appropriate fecal and chemical water quality parameters
(CDC, 2009).
A facility’s water emergency and preparedness plan will include detailed information and
procedures to enable facility staff and remediation personnel to respond to and recover from
interruption of the facility’s water supply. This plan will typically identify alternate water
sources and mitigation procedures (e.g., posting signage that water is not safe for consumption,
employing alternate procedures if tap water is not appropriate for process use). In addition to
considering alternate water supplies, facility managers can benefit from planning for actions to
remediate the facility’s water supply, distribution, and building plumbing systems (also known as
46
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1270
1271
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1273
1274
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1282
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1298
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“premise plumbing”). Mitigation planning includes identifying water system repair and
rehabilitation companies that can quickly respond following a flood event, having documents
ready to assist in the system repair and rehabilitation process, and ensuring that the facility water
system is effectively flushed to remove contaminated water and contaminant residues (Bartrand
et al., 2018).
The guidance documents from CDC and American Water Works Association (AWWA) on
developing emergency water supply plans for healthcare facilities may be helpful to animal
growth and production facilities. The CDC and AWWA’s Emergency Water Supply Planning
Guide for Healthcare Facilities has checklists and decision trees that could be adapted to food
production facilities during the preparation for, and response to, a water supply interruption
(CDC AWWA, 2012). Similar guidance could be developed to provide information and tools to
food processing facilities interested in developing water preparedness plans.
Steps and considerations in preparing a food processing facility water preparedness plan include
(Figure 7-1):
1: Identify the facility’s water supply and operations team.
2: Understand facility water usage by conducting a water use audit, including assessment of
facility water taps and processes that could present risks that may need to be mitigated if the
water supply is suspected to have been compromised by flooding.
3: Analyze the facility’s emergency water supply alternatives.
o Review and incorporate applicable rules and guidance from local, state and federal
authorities.
o Identify alternate sources of water that can be obtained and used for facility
operations, including drinking or use in facility processes.
o Identify critical partners that can assist with obtaining alternate water sources or
rehabilitate the facility’s established water source and building plumbing system.
4: Develop and test the Emergency Water Supply Plan.
o Develop messaging examples to provide facility workers with guidance on
consuming or using water in the facility.
47
1300 o Develop alternate procedures in event the facility water supply is compromised and
1301 not suitable for use or consumption.
1302 o Educate and train staff on water-related preparedness for the facility.
1303
48
1304
1305
1306
1307
1308
1309
1310
1311
1312
1313
1314
1315
1316
1317
1318
1319
1320
1321
1322
1323
1324
1325
1326
1327
1328
1329
1330
1331
1332
1333
1334
Responses to Charge Question #8
What technologies are appropriate for the replacement of liquid water in food production
and food processing areas (i.e., foam, mist, or dry chemicals)? What advanced emerging
technologies may reduce the need or volume for water in processing?
Alternate water-sparing processes may be considered, such as air chilling a product in place of
chilling in a water bath and using recycled water and wastewater for specific purposes (refer to
Charge Question #2). Recycled water can be used for product-contact equipment rinsing,
provided that the provisions of 9 CFR 416.2(g)(3) and (4), where applicable, are properly
addressed (Anonymous, 1999; USDA FSIS, 1999). Strategies that prevent contamination from
being brought into a clean processing area may enhance the overall effectiveness of a cleaning
program, such as using boot disinfection stations and limiting wheeled equipment to specific
zones. Staff training with regular updates can maintain and reinforce cleaning and water-sparing
behaviors.
Cleaning, sanitizing and disinfection are critical components of a facility’s operations program
during routine operations and for recovery activities following a flood or other contamination
event. Cleaning is the process of removing contaminants from a surface that could be harmful to
human or animal health, damage equipment, lead to process inefficiency, or impact product
integrity or safety. Cleaning processes and chemical products are not designed to kill bacteria,
viruses or fungi, but rather to remove them from surfaces along with dirt, oils, and other
inorganic and organic materials. Sanitizing and disinfecting (refer to Glossary) are related
concepts, as both are focused on killing or inactivating microorganisms, including pathogens.
Disinfectant products and processes are those that result in a more rigorous removal or
inactivation of microorganisms of public health concern than sanitizing products (sanitizers) and
sanitizing processes (Appendix #2). For example, there are no sanitizer-only products with EPA-
approved virus claims, but there are sanitizer-only products with EPA-approved bacteria claims,
as vegetative bacteria (though not bacterial spores) are generally easier to inactivate than viruses
(Sobsey, 1989).
49
1335
1336
1337
1338
1339
1340
1341
1342
1343
1344
1345
1346
1347
1348
1349
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1353
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1356
1357
1358
1359
1360
1361
1362
1363
1364
1365
When choosing a sanitizer or disinfectant, it is important to consider what level of sanitizing or
disinfection is indicated for each facility process, and what the product is registered to do (i.e.,
the label claims). Some products can have both claims, as a sanitizer and as a disinfectant,
depending on variables such as concentration and contact times (Appendix #2).
The general steps in cleaning and sanitizing food contact surfaces are site-specific and variable.
Wet cleaning of an establishment includes a cleaning step, which may include the use of
detergents, to remove, as much as possible, organic matter and may be accompanied by physical
actions, such as scrubbing, pressure, etc. The sanitizer(s) is(are) applied after cleaning. Dry
cleaning protocols (refer to Glossary) also include mechanical removal of soil or residue, aided
with vacuum, compressed air, or compressed steam, and wiping with alcohol-based swabs or
moistened pads, followed by towel drying (Table 8-1). Dry sanitizing and disinfection treatments
can reduce microbial contamination, using products based on a variety of mechanisms of
antimicrobial action and approved by the EPA for use on food contact surfaces (Table 8-2). A
critical final step is often a disinfectant treatment that may intentionally leave an antimicrobial
residue.
Most cleaning, sanitizing and disinfection approaches standard in the protein food processing
industry are water intensive. Several water-sparing technologies may have uses that could reduce
dependence on water for these basic steps (Tables 8-1 and 8-2). Many of these technologies were
developed first for use in dry and ready-to-eat food processing environments, where waterless
cleaning and disinfection has been widely adopted, and may also have applications in meat and
poultry processing. Novel sanitizers and disinfectant strategies may offer similar bacterial load
reduction and disinfection while using less water. Whole room or closed chamber treatments
with fogs or ultraviolet light may help reduce bacterial loads on exposed surfaces without
requiring any water at all. Surface treatment preparations that do not require a final rinse may
reduce water use.
Sanitizers and disinfectants for use on food contact surfaces are registered as antimicrobial
pesticide products with the EPA under FIFRA (refer to Charge Question #3), which reviews data
from standard microbial reduction effectiveness assays to validate public health claims for
50
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1371
1372
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particular uses, such as treatment of hard surfaces (US EPA 2012c, US EPA 2018b). Whole
room treatments using disinfectant products delivered as a fog are registered for that delivery
system. But novel cleaning and sanitizing products may help reduce use of water. For instance,
cleaning solutions based on quaternary ammonium compounds can be used with pre-moistened
wipes as an alternative to well-established chlorine-based wipes. Sanitizing solutions based on
~60% isopropyl alcohol and quaternary ammonium compounds may introduce little water.
Ultraviolet light treatments and ozone applications may have applications in enclosed spaces, as
an adjunct to other treatments, with adequate precautions for worker safety. These alternatives
(ultraviolet light and ozone applications) are regulated by the EPA as devices, and are not
registered, nor granted health claims by the Agency (US EPA 2020). EPA is also developing
regulatory strategies for the new and rapidly expanding category of surface treatments or
coatings with sustained antimicrobial properties. Copper alloys, which are registered by the EPA
as surface antibacterials with limited sanitization claims and not for food contact surfaces (US
EPA 2016), have been described for use in hospitals and other clinical facilities, and have limited
though long-lasting effects, and validated bacterial effect claims (Muller et al., 2016). Some
coatings are registered but do not have public health pathogen claims. Silver alloys have been
incorporated into poured floors and other surfaces to make them more mold and mildew
resistant. Surface treatments for food contact surfaces may offer a longer lasting residual
antimicrobial effect, though published practical experience with them is limited. Similar
experience is beginning to be reported from healthcare settings (Boyce, 2016). Once a standard
test protocol is developed, including assessment of how long effectiveness lasts, more coatings
with residual antimicrobial effects lasting for weeks or months are likely to be registered with
specific health claims. In the future, with more published experience and EPA registration, such
technologies may offer efficient sanitizing and disinfection in combination with more routine
cleaning methods, while using less water.
When considering a novel technology, it is important to evaluate several critical points:
1. Is the new technology involving sanitizing or disinfecting registered with the EPA as either a
sanitizer or as a disinfectant for use on food contact surfaces? The appropriate criteria for one
51
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1399
1400
1401
1402
1403
1404
1405
1406
1407
1408
1409
1410
1411
1412
1413
1414
1415
1416
1417
1418
1419
or the other (Appendix #2), need to be met if the technology is to be used for those purposes
on a food contact surface. If the new technology is a device or surface coating, the company
will need to evaluate the available antimicrobial effect data, as these are not registered with
the EPA for health claims.
2. What published or other experience is available showing that in a practical use case the
technology achieved reductions in both the pathogen load and in the volume of water used in
cleaning and disinfection? The nature of that experience needs to be carefully considered,
including whether the impact was measurable with standard monitoring tests already in use
in the facility’s water use plan. A hierarchy of evidence has been described for evaluating
products used in the health care sector (McDonald and Arduino, 2013). A similar approach
may be useful in evaluating reported experiences in the food processing sector.
3. Does the technology make economic sense, so the value of the water saved at least equals the
cost of applying the novel strategy? That may include the cost of water piped in, and
sewerage costs incurred, as well as the cost of implementing the new technology
(Timmermans, 2014).
4. Is the new process readily accepted by the workforce? What additional training and ongoing
reinforcement will be needed?
5. How can existing sanitization performance standards and sanitary standard operating
procedures be adapted to include the new process? Are ongoing environmental and product
monitoring tests in place to provide ongoing assessment of the impact on microbial targets?
6. If it is adopted, what evaluation at future time points will be made, to see what the impact is
on the actual water use as measured in the ongoing water management plan?
52
1420 Tables
1421
1422 Table 1-1. Estimated amount of water used during processing by species
1423
Species
Broiler
chickens
Water Usage
18.9 to 37.8 (average 26.5) L per 2.3
kg broiler (Avula et al., 2009;
Northcutt and Jones, 2004; Micciche
et al., 2018)
Adjusted per Kg
Average
8.5 to 11.5 L per
kg of broiler meat
Comments
Avula et al., 2009/
Calculated usage by
processing step
Micciche et al., 2018
Beef
4,947 liters by ton LCW
1
(Li et al.,
2018)
4,200 to 16,600 liters by ton LCW
(Jones 1993)
2,299 liters per carcass (Beckett and
Oltjen, 1993)
3,000 to 5,000 (small
establishments) up to 10,000 to
11,000 (large establishments) liters
per ton (Warnecke et al. 2008)
4.2 L per kg of
meat
3 to 5 (small
establishments) up
to 10 to 11 (large
establishments)
liters per kg
Li et al. 2018. Includes
water for processing and
cleaning and sanitizing
Jones, 1993. Estimated
water use in beef
processing ranging from
4,200 to 16,600 L/t
LCW
Turkey
41.6 to 87 liters per turkey
N/A
CAST, 1995
1424
1425
1
Liter per metric ton live carcass weight.
1426
53
1427 Table 1-2. Water usage in broiler processing.
1428
Processing Step
Water Usage
Is Water Conservation/Reuse Feasible?
(L/Bird)
Live receiving
0
Some discussion about recycling some water to be used as
a primary rinse for cleaning live chicken drawers, but we
are unaware of anyone doing this practice.
Hanging
0.19
Little to no water used
Stunning
0
No water used
Bleeding
0
No water used
Scalding
0.95
Yes. Refer to Russel, 2013
De-feathering
1.14
Potable water is used because it directly contacts food.
Evisceration
7.57
Refer to Carcass washes
Carcass washes
4.35
There is work done to reclaim the water from the
Inside/Outside bird washers, treat that with PAA and
reuse it on other areas upstream.
Pre-Chiller/Chiller
2.12
Yes. Refer to Amorim, 2007, Avula et al. 2009, Blevins,
2020; Northcutt, 2008, Russell, 2013, Matsumura, 2008
Cut-up/deboning
3.03
The committee is unaware of reuse in these steps
Packing
1.14
The committee is unaware of reuse in these steps
1429
54
1430 Table 1-3. Water usage in beef processing. Taken from Li et al. (2018), Pype et al. (2016) and
1431 Warnecke et al. (2008)
1
1432
Processing Step
Water
Percent of
Comments
Usage Total Water
(L/t LCW)
2
Consumption
Live receiving
247
7-14
Stunning, Bleeding and
1418
44-60
Li et al. (2018). The kill floor (live
Dressing (head, hoof, receiving, stunning, bleeding
hide removal)
3
dressing) represented 28.7% of the
total water used, including 6.5% for
antimicrobial interventions
(prewash; carcass wash; organic acid
spray).
Evisceration
537
11
Rendering
647
2-13
Carcass Chilling
2
Fabrication (boning)
333
5-10
Cleaning and sanitation
LD
4
22-24
Li et al. (2018). Water with high
pressure (60°C) at processing shifts:
11.2%; water with high pressure
(60°C) at sanitizing shift: 12.8%;
subtotal: 24% of total water used in
the plant
1433
1434
1
There is limited information on the water use in amenities and plan service (e.g., cooling,
1435 heating) services.
1436
2
Liter per metric ton live carcass weight. All data normalized per metric ton live cattle weight (t
1437 LCW) with an estimated live weight of 635 kg per cattle. Approximately 2.94 liters per kg of
1438 LCW.
1439
3
The wash cabinets are areas for potential water reuse and water conservation.
1440
4
LD =limited data. There are large variabilities in the use of water for cleaning and sanitizing.
1441
55
1442 Table 1-4. Modified audit grid of potential water conservation and savings opportunities in protein processing.
1443 Provided by Varsha Shah, Sr. Program Leader, Food and Protein RD&E, Ecolab.
1444
Opportunity Location System Type Comments
Dry Pick Up
Sanitation
Sanitation
Program
Water
Minimization
Completing a good dry pick up of excess packaging
material, product waste and excessive soils prior to
implementing the pre-rinse can save time, energy and
water.
Optimize cleaning
Plant
CIP/COP
1
Water
minimization
Chose right cleaner for soil type, water quality, surface
to be treated, method of application and based on
environmental guidelines.
Chilled and hot
water leaks
Utilities
Factory
Water
Minimization,
Leaks
Water leaks are always an issue and eliminating leaks
will conserve water.
Condensate return
and traps
Utilities
Factory
Condensate
Condensate systems and steam traps will result in some
water savings, but mostly will result in energy savings.
Poor steam trap
operation
Utilities
Factory
Steam Systems,
Leaks
Leaking steam traps will waste energy and water as
both steam and condensate.
Re-use sample
water
Utilities
Factory
Water Reuse
Anywhere where a stream of water is used
continuously for either taking a sample, or as sample
cooler water, the water should always be collected and
repurposed.
Hand wash stations
Sanitation
Factory
Equipment
Shutdown
Hand wash stations left running wastes water
Hose stations
Sanitation
Factory
Equipment
Shutdown, Water
Minimization
Hoses are used for floor cleaning and equipment wash
down. Often, they are left running, have had nozzles
cut off or have orifices too large for the job. High
pressure is generally more efficient than low pressure
systems.
56
Opportunity Location System Type Comments
Line shutdown
Plant
Factory
Water
When a line stops or product is no longer running, all
Minimization water systems need to be turned-off. This also results
in significant energy savings.
Weekend water
Plant
Factory
Water
Shut all equipment when the plant is shut down. While
consumption Minimization a plant is shut down and not operating over a weekend,
it should not be using much, if any, water if all
equipment is shut down.
Metering and
Plant
Metering
Most operations do not have water meters at locations
monitoring where flow rates need to be monitored and when they
do, they typically do not do a good job recording or
reacting. A good metering and monitoring program can
save 10% of plant water use.
Water reuse system
Sanitation
Production
Water Reuse
Chicken plants especially have water savings
opportunities to re-use and recycle chiller water. This
system could be evaluated for water savings from
flumes as well.
Inside outside bird
Sanitation
Production
Water Reuse
Chicken plants especially have water savings
washer (IOBW) opportunities to re-use and recycle IOBW systems.
Optimization of
Sanitation
Sanitation
leaks
COP tank systems can overflow or leak, consuming
cleaning-out-of
place (COP
1
)
Program water.
system
RO/membrane rinse
Sanitation
Sanitation
Water
These systems use a large amount of water and many
optimizations Program Minimization steps with high flow to wash and rinse. Good rinse
studies can optimize rinses and save large volumes of
water.
1445
1446
1
CIP and COP: Refer to Glossary
1447
57
1448 Table 4-1. Summarized charge questions 4 and 5 for the committee translated into the risk
1449 assessment framework.
1450
Charge
Question
#4a, b, d
Summarized committee
question(s)
How do residual contaminants in
water used for animal
production, slaughter, and
processing affect product quality
and safety? What are the quality
implications and public health
risks associated with
Risk assessment
question(s)
Can reconditioned water
reduce product quality
and safety? Can this
change result in
increased public health
risks?
Risk analysis step(s)
Hazard identification
contaminants at levels
anticipated for reconditioned
water?
#4c
How might FSIS and industry
best assess those implications
and risks?
Quantify the additional
public health risk from
using reconditioned
water (vs status-quo
potable water usage)
Comparative risk
assessment (i.e.,
exposure assessment,
hazard characterization,
risk characterization)
#5
What are the best ways to assure
and/or monitor the quality and
safety of alternatively sourced
water used in FSIS-regulated
operations?
How do we monitor and
control public health
risks from using
reconditioned water?
Risk management, risk
communication
1451
1452
58
1453
1454
Table 8-1. Cleaning mechanisms with potential for decreasing facility water use.
Cleaning Type
Mechanism/Delivery
Mechanical
Manual tools (brushes, cloths, scrapers, scrubbing)
Detergent wipes, Dry ice/CO2
Vacuum
Chemical
Thermal
Compressed air/High-pressure “Dry ice/CO2
Ultrasonic bath (for COP)
Enzymatic foam
Spray
Atomizing
“Dry” Steam
1455
1456
59
1457
1458
1459
Table 8-2. Sanitization or disinfection products and devices with potential for decreasing facility
water use.
Disinfectant Type
Product/Active Component
Comments
Chemical
Chlorine, chlorine dioxide,
Fogging uses little water, but is not
hydrogen peroxide, Quaternary recommended for primary disinfection
ammonium compounds,
ammonia, ozone, photo plasma
Thermal
Antimicrobial materials or
coatings
Steam or dry heat
May reduce microbial burden on
surfaces and floors (less frequent and
lower use of water for cleaning and
disinfection)
Evaporates on contact. Takes time to
ensure all surfaces are contacted.
Irradiation
Ultraviolet light
Effect limited to surfaces exposed to
ultraviolet light; so residual
contamination can remain on surfaces in
shadow.
1460
1461
60
u
rp
os
e:
• Notfor
foo
d
con
ta
ct
ap
plic
at
ions
I Re-used
water
I
•
No
microb
i
ological
requ
i
rements
~
I
Pur
pos
e:
• F
oo
d
co
nt
act
appli
catio
ns (
food
or
foo
d
co
nt
act
s
urf
a
ce
s)
for
consumer
food
safety
Ir
Is
contact
of t
he
r
euse
water
(as
rec
laimed/
recycled)
with
food
materials
im
poss
ib
le
due
to
pass
i
ve
management,
i.e.
des
ig
n
and
infrast
r
ucture
of
Foo
d
opera
t
ion?
N
y
Is
active
management
feas
i
ble
to
consistently
exclude
contact
of
r
euse
water
with
food
mater
ial
s?
N
'
• Notfit-for-
purpose
•
Do
not
use
this
reuse
water
source
or
supply
wi
thout
recond
itioning
y
'
•
Fit-for-purpose
for
all not-for-
food
contact
app
licat
ions
•
Ass
u
re
water
is
separately
stored
and
transported
from
water
for
food
contact
app
l
ications
•
Verify
active
management
when
additionally
nee
d
ed
• Mi
crobio
lo
gi
cal
Safe
ty
requirement:
re
-
use
water
shou
ld
not
comprom
i
se
consumer
safety
Are
microbiological
hazards
absent
in
the
re
use
water
or
present
at
acceptable
leve
ls,
i.e.
levels
t
hat
do
not
comprom
i
se
the
consume
r
food
safety
of
the
concerned
ingredient/food?
N
'
Can
reuse
water
be
treated
Y
to
avoid
presence
of
hazards
~
or to
control
haza
rds
to
acceptab
le l
evels?
N
'
Can
applicat
i
on
of
reuse
water
be
limited
to
applications
other
than
as
food
ingred
ient
or
those
not
contam
in
at
i
ng
food
materials
or
contact
surfaces?
N
•
Not
fit-for-
purpose.
•
Consider
only
"not-for-food
contact"
applications
that
effectively
exclude
contact
of
reuse
water
with
food
materials
or
contact
surfaces
y
-
•
Fit-for-pu
r
po
se
for
intentional
a
nd
unintentional
food
contact
applications
•
Build
active
management
into
your
food
safety
management
system,
including
validat
i
on
of
control
measures
as
well
as
monitoring
and
ver
i
fication
of
control
dur
i
ng
d
ay
-
to-day
operation
•
Fit
-
for
-
purpo
se
only
for
food
application
s
other
than
as
in
gredi
e
nt
or
final
cleaning/
wa
s
hing
•
Build
active
management
i
nto
your
food
safety
management
system,
including
validat
i
on,
monitoring
and
ver
i
fication
1462 Figures
1463
1464 Figure 4-1. Example of a risk-based decision tree to match fit-for-purpose applications of reuse
1465 water with either a food contact application or a not-for-food-contact application (from
1466 FAO/WHO, 2019).
1467
1468
1469
61
1474
1475
1476
1477
1478
1479
1480
1481
1482
1483
1484
1485
1486
1487
1488
1489
Appendices
Appendix #1. Critical water usage in animal growth and processing facilities
• Consumption and essential health & safety functions
• Handwashing
• Drinking
• Food production and preparation
• Animal care
• Fire suppression
• Equipment and sanitary purposes
• Flushing toilets
• Cleaning and sanitizing/disinfecting facility and equipment
• Heating, ventilation, and air conditioning
63
1490
1491
1492
1493
1494
1495
1496
1497
1498
1499
1500
1501
1502
1503
1504
1505
Appendix #2. Sanitizers and disinfectants. Examples of measures of effectiveness required for
EPA registration for use on hard food contact surfaces.
• Sanitizers for use on hard surfaces (Food contact surfaces) (US EPA 2012c):
• After treatment, 10
5
reduction in numbers of Salmonella enterica and
Staphylococcus aureus
• No efficacy claims for viruses or other non-bacterial pathogens
• Broad spectrum disinfectant on hard non-porous environmental surfaces (US EPA
2018b):
• 60 test surfaces (carriers) with 10
5
-10
6
Salmonella enterica/carrier
• 60 test surfaces (carriers) with 10
6
-10
7
Staphylococcus aureus/carrier
• After treatment, no more than 1 carrier positive for Salmonella, and 3 positives
for Staphylococcus
• Disinfectant claims for viruses can also be based on efficacy testing
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Glossary
Activated sludge. A wastewater treatment process where sewage or industrial wastewaters are
treated by aeration and a biological floc, or sludge blanket, composed of bacteria and protozoa to
remove organic pollutants.
Alternatively sourced. Water not from a municipal water treatment plant.
Antimicrobial agent. Substance used to preserve food by preventing growth of microorganisms
and subsequent spoilage, including fungistats, mold and rope inhibitors, and the effects listed by
the National Academy of Sciences/National Research Council under "preservatives" (21 CFR
170.3(o)(2)).
Biological oxygen demand. The amount of oxygen consumed by bacteria and other
microorganisms while they decompose organic matter under aerobic conditions at a specified
temperature.
Chemical oxygen demand (COD). The amount of oxygen consumed to chemically oxidize
organic contaminants in water to inorganic end products. It is a measure of water and wastewater
quality, and it is used to monitor water treatment plant efficiency. This test is based on the
principle that strong oxidizing agents in acidic environments will oxidize almost any organic
compound to carbon dioxide.
Clean. To remove soil, dirt, grease – any objectionable, visible material.
Cleaning-In-Place. A process that uses water rinses, hot caustic and/or acid recirculation,
precise temperatures, and turbulence to clean soils and bacteria microbial contaminants from the
inside surfaces of food production equipment, Equipment such as, mixing tanks, pumps, valves,
storage vessels.
Cleaning-Out-of-Place. A process of cleaning equipment items at a designated cleaning station.
Equipment could include fittings, clamps, product handling utensils, tank vents, pump rotors,
impellers, casings, hoses, etc.
Clean water. Water which does not compromise the safety of the food in the context of its use.
Cleaning product/compound/substance. A substance or mixture of substances (such as
chemical or biological substances) that is intended to clean away or remove inanimate material
from a surface, water or air.
Contaminant. Any undesirable chemical substance, microorganism or physical matter present in
a sample.
Disinfection. A process performed to eliminate many or all pathogenic microorganisms, except
bacterial spores, in a liquid (e.g., water) or on inanimate objects.
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Dissolved air flotation. A water treatment process that clarifies wastewaters (or other waters) by
the removal of suspended matter such as oil or solids. The removal is achieved by dissolving air
in the water or wastewater under pressure and then releasing the air at atmospheric pressure in a
flotation tank basin. The released air forms tiny bubbles which adhere to the suspended matter
causing the suspended matter to float to the surface of the water where it may then be removed
by a skimming device.
Dry cleaning. The removal of food residue with mechanical action.
Fecal coliform. A type of bacterial count as determined by approved methods of analysis (40
CFR 136.3).
GRAS (generally recognized as safe). A substance that is generally recognized, among
qualified experts, as having been adequately shown to be safe under the conditions of its
intended use, or unless the use of the substance is otherwise excepted from the definition of a
food additive. The general recognition of safety is based on 1) scientific procedures, through the
views of experts qualified by scientific training and experience to evaluate the safety of
substances directly or indirectly added to food, or 2) history of the use of the substance prior to
January 1, 1958 (21 CFR 170.3). In 2016, FDA issued a final rule that amended and clarified the
criteria for when the use of a substance in food for humans or animals is not subject to the
premarket approval requirements of the Federal Food, Drug, and Cosmetic Act because the
substance is considered GRAS under the conditions of its intended use (FDA 2016).
Heterotrophic plate count. A variety of simple culture-based tests that are intended to recover a
wide range of heterotrophic microorganisms, which are microorganisms that require organic
carbon for growth and include bacteria, yeasts and molds. This test was formerly known as
“standard plate count,” and the test methodology involves a wide range of test conditions, such
as incubation temperatures varying from 20°C to 40°C, or incubation times varying from a few
hours to a few weeks, and nutrient conditions of the medium varying from low to high (WHO,
2001).
Indicators. Microorganisms whose presence in water indicates the potential presence of a public
health hazard.
Library-dependent method. A range of bacterial source tracking techniques based on the
isolation, phenotyping, and genotyping of indicator bacteria from different sources, such as fecal
sources and water samples (Mott and Smith, 2011).
Moving bed biofilm reactor. A water processing system that optimizes the use of a sludge
activated sand biofilter to utilize the whole tank volume for biomass growth (Ødegaard et al.,
1994).
No contact. Water in the meat processing environment that does not touch product or product
contact surfaces (e.g., environmental sanitation of non-meat product contact surfaces inside the
processing environment, as a diluent for cleaning and sanitizing chemicals used in CIP systems
or manual sanitation, excluding the final CIP water rinse).
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Pathogens. Disease-causing organisms (generally certain viruses, bacteria, protozoa, or fungi).
Pathogen indicators. A substance that indicates the potential for human infectious disease
(Clean Water Act, section 502(253)). Enterococci and generic E. coli are indicators. They do not
cause human illness because they are not human pathogens, but they indicate the presence of
fecal contamination.
Potable water. Drinking water that meets or exceeds state and federal drinking water standards.
Quantitative microbial risk assessment. The application of probabilistic models to estimate the
order of magnitude of risk of infection and illness when a population is exposed to specific
microbiological hazards.
Reclaimed water. Water that was originally a constituent of a food, has been removed from the
food by a process step, and has been subsequently reconditioned when necessary, such that it
may be reused in a subsequent food manufacturing operation. Water that has been treated to be
fit-for-purpose for reusing or recycling.
Reconditioning. The treatment of water intended for reuse by means designed to reduce or
eliminate microbiological, chemical, and physical contaminants, according to its intended use.
Reconditioned water. Water that has never contained human waste and is returned to safe
drinking water standards via treatment by an onsite advanced wastewater treatment
facility. Reconditioned water can be used on raw product and throughout the facility provided
that product or equipment that contacts reconditioned water receives a final rinse with non-
reconditioned water that also meets safe drinking water standards. Reconditioned water cannot
be used on ready-to-eat products (citation: 9 CFR 416.2(g)(4)):
Recycled water. Water, other than first use or reclaimed water, that has been obtained from a
food manufacturing operation and has been reconditioned when necessary, such that it may be
reused in a subsequent food manufacturing operation.
Residual contaminants. Impurities remaining in water after the implementation of a remedial
action.
Reuse. The recovery of water from a processing step, including from the food component itself;
its reconditioning treatment, if applicable; and its subsequent use in a food manufacturing
operation.
Reused water. Recycled and reclaimed water.
Sanitizers. Antimicrobial pesticides used to reduce, but not necessarily eliminate,
microorganisms from the inanimate environment to levels considered safe as determined by
public health codes or regulations. Sanitize. To reduce microorganisms of public health
importance (and other undesirable microorganisms) to levels considered safe. Sanitized surface.
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Adequately treat cleaned surfaces by a process that is effective in destroying vegetative cells of
pathogens, and in substantially reducing numbers of other undesirable microorganisms, but
without adversely affecting the product or its safety for the consumer.
Sequencing batch reactors. A type of activated sludge process for the treatment of wastewater.
Source Water. A place from which water is obtained; a municipal water supplier, a well, a
spring, a fountain, etc. More generally: a place from which water can be obtained.
Turbidity. The measure of relative clarity of a liquid. It is an optical characteristic of water and
is a measurement of the amount of light that is scattered by material in the water when a light is
shined through the water sample. The higher the intensity of scattered light, the higher the
turbidity. Material that causes water to be turbid include clay, silt, very tiny inorganic and
organic matter, algae, dissolved colored organic compounds, and plankton and other microscopic
organisms.
Wastewater. Used water.
Water conservation. More efficient use of water, resulting in reduced demand for water.
Sometimes called “end-use efficiency” or “demand management.”
Wet cleaning. The process of removing food residue with water and chemicals.
Water reuse. Water, ice, and solutions used to wash or chill product, which is maintained free of
contamination and recirculated on the processing line. Water can only be reused for the same
purpose (e.g., water used at evisceration can only be reused within the evisceration
process). Reused water can be treated but does not need to meet safe drinking water standards.
(citation: 9 CFR 416.2(g)(2-3).
Water reconditioning. The treatment of water intended for reuse by means designed to reduce
or eliminate microbiological, chemical, and physical contaminants, according to its intended use.
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