4 replies to this topic

[RazM4tt]

Happy Wednesday everyone!

 

I'm hitting a dead end trying to figure out the requirements for my facility for water testing. For context, we make nutritional supplements/products. Currently we do quarterly water testing of each hand sink used within the facility (total of 10), each washroom (4) and each production room that has water used for cleaning equipment (4), I also added the mop sink to the rotation that is used to mix the chemicals that are used to clean the rooms. We also do a monthly test of our "purified water" which is used as an ingredient in some of our products and fermentations. We do a full panel for micro including indicator organisms and pathogen detection on all of these samples.

 

Now moving to the issue at hand, which is the annual water testing. The person running the program before I came along has the annual water testing being done referencing the following:

 

-CFR Title 40 Chapter 1 Subpart D part 141 Appendix A to Subpart O-Regulated Contaminants

-CFR Title 21, Volume 2 Part 165 Subpart B

-EPA-National Primary Drinking Water Regulations Complete Table

 

I suspect (due to the vast amount of over-testing) that the previous EM Specialist was very by the book. If it said it had to be done, she did it. Now I am dealing with a $4000 annual water testing requirement that I am trying to wrap my head around. The following results (see below) are reported for a sample of "purified water" (i do find value in this as it is an ingredient) and also a composite of the "wash water" (Handsinks + washroom water). We also pull the annual report for the city water we use in the facility to keep on file. Could someone help me figure out why she decided to do this much testing, and where the CFR and EPA requirements are applicable, in what type of facilities? It feels like she had set up the program to have testing requirements similar to an actual water treatment facility (the annual water test result last year was 87 pages long). Thank you for all the help!

 

Total Coliform (CFU / mL) Fecal Coliform (CFU / mL) Turbidity Escherichia coli

Haloacetic Acid (HAA5) Trihalomethanes (Total)

 

pH Free Chlorine Chloramine Temperature-At time of
collection.

 

Total Organic Carbon Total Disslved Solids Nitrate as N (NO3N) Nitrate as N (NO2N) Nitrate /Nitrate as N  Total Hardness (EDTA) Fluoride Chloride Sulfate as SO4

 

Aluminum Arsenic Barium Cadmium Copper  Cyanide Lead  Mercury Nickle Selenium 

 

[kconf]

You are right - she went little too far than needed. I would just do annual microbial testing on APC, coli, ecoli. Your supplier provides you with the other results. 

If you are using water in your formula then you can test more frequently, but spending $4000 on water testing alone sounds absurd. 

[RazM4tt]

You are right - she went little too far than needed. I would just do annual microbial testing on APC, coli, ecoli. Your supplier provides you with the other results. 

If you are using water in your formula then you can test more frequently, but spending $4000 on water testing alone sounds absurd. 

 Yes, we do a Monthly full micro panel for the water used as an ingredient. All other "wash water" gets a full micro panel once a quarter. Not just HPC and coliform but the whole test (HPC, Coliform, E.coli, S. aureus, Y&M, Salmonella, P. aureginosa). This is individual testing on each handsink/washroom/water source used in the facility for a total of about 20 sites / quarter. 

[G M]

This sounds like overkill.  Do you have any history of unacceptable results?

[kingstudruler1]

Seems like a lot to me as well.   I think its good to test your source water feeding the "purifier" and the purified water.  You might just rotate through the other  sample sites and not do them all every quarter (reduce freqency).   I probably would not test for all of your paramers either.   For instance, it is not good to have heavy metals in your water.   However, if they are at a hand sink etc, the liklihood of them causing product contamination / health risk is next to zero.   

 

Unless of course there are different regulations for supplement MFG or know inssues with the distribution system.   

 

Why - perhaps its easier to test everything than to have to justify how you picked fewer sample sites and / or tests?