The Emerging Water Crisis

FDA regulations implicitly assume EPA-compliant municipal water is safe for consumption. But, unfortunately, this is not always the case. EPA’s rules for public water systems require that utilities meet treatment standards for 95 percent of the water they distribute. EPA does not dictate how water must be treated, and not all municipal water is disinfected the same way, and some is not disinfected at all. This means that EPA-compliant water could be contaminated with Salmonella spp., viruses, or other pathogens. For beverage manufacturers that use between 10,000 and 500,000 gallons of municipal water per day, 5 percent contamination could be significant, not only for the product but also for potential cross-contamination within the plant.

“FSMA makes clear that food and beverage manufacturers need to ensure the biological integrity of water if they use it as an ingredient. But if they use municipal water, it is not clear that they need to do an appropriate risk assessment,” says Phyllis Posy, vice president, strategic services and regulatory affairs, Atlantium Technologies, which makes UV-light based water disinfection and treatment equipment for industry and municipalities.

Further complicating matters, EPA’s Revised Total Coliform Rule for public water systems, which went into effect April 1, 2016, changes the focus for utilities from public notification of problems to “find and fix” without notification, Posy says. The revised rule focuses on detecting and reducing maximum levels of E. coli, a proxy for other contaminants, including viruses, which are not tested. “Reduction in fecal contamination should reduce the potential risk from all waterborne pathogens including bacteria, parasitic protozoa, and their associated illnesses,” EPA explains. Under this new framework, manufacturers and the public may never know of a contamination problem.

“The intent of FSMA is to ensure safer food, but the letter of the law allows a lot of wiggle room,” Posy tells Food Quality & Safety.

Municipal water systems, most of which are aging and needing repair, are also prone to other forms of contamination, including lead, as residents and businesses in Flint, Mich. and counties in Alabama have found. Unsafe levels of industrial chemicals, including PFAS (poly- and perfluoroalkyl substances), have been found in 66 public water supplies serving 6 million people. The chemicals, commonly used in manufacturing household products, have been linked to cancers and other serious health problems. In many rural areas where people rely on wells and groundwater, contamination from hydraulic fracturing or “fracking” is a major concern. And when a natural disaster strikes, such as a Hurricane Katrina or Sandy, municipal water frequently requires a boil advisory—something manufacturers are unable to do.

“In case of a natural disaster or contamination, if the beverage manufacturer hasn’t done anything in advance, it’s too late,” says Posy. “The question is not what they should do now when there’s a mess, but what should they have done in advance? They should have done a risk assessment to understand where their water’s coming from, and not take water for granted.”

Nearly all large beverage manufacturers do treat incoming municipal water not only for potential contamination but also because of flavor profile requirements; cola syrup simply doesn’t taste right when added to chlorinated water. “But when there’s not a flavor profile issue involved, smaller beverage manufacturers may assume that because the municipal water’s good enough to drink, it must be good enough to make food and beverages,” Posy says. “Unfortunately, that’s not always the case.”

Beverage manufacturers today have a large and growing array of test and treatment technologies, depending upon their products and manufacturing needs. Similar to equipment used to recycle water waste within the plant, these can include activated carbon filters to remove sediment particles, chlorine, bromine, and organics; reverse osmosis to remove dissolved inorganic solids; micro-, ultra-, and even nano-filtration membrane systems to separate microorganisms and total dissolved solids; ion-exchange resins or polymers to remove heavy metals and maintain color and taste consistency; and UV-light and ozone systems to kill bacteria in water and on surfaces and to sanitize storage tanks, vessels, and piping. Large bottling facilities always test their incoming water to measure chemicals and microbial contaminants, and test finished product for QC and safety.