NACMCF 2018-2020 Water Reuse

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
Nature of the Contaminants....................................................................................................... 23
Chemical Contaminants, Including Chemical Sanitizers.......................................................... 24
Biological Contaminants ........................................................................................................... 26
Contaminants at Different Processing Steps ............................................................................. 27
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
Monitoring Quality and Safety of Alternatively Sourced Water .............................................. 36
Pond Water................................................................................................................................ 41
Transport Water......................................................................................................................... 42
Processing Water....................................................................................................................... 42
1
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)1 ............................................................................................................. 55
Table 1-4. Modified audit grid of potential water conservation and savings opportunities in
protein processing. .................................................................................................................... 56
Table 4-1. Summarized charge questions 4 and 5 for the committee translated into the risk
assessment framework............................................................................................................... 58
Table 8-1. Cleaning mechanisms with potential for decreasing facility water use................... 59
Table 8-2. Sanitization or disinfection products and devices with potential for decreasing
facility water use. ...................................................................................................................... 60
Figures........................................................................................................................................... 61
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
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
Appendix #2. Sanitizers and disinfectants. Examples of measures of effectiveness required for
EPA registration for use on hard food contact surfaces. ........................................................... 64
Glossary ........................................................................................................................................ 65
References..................................................................................................................................... 69
2
1 FSIS Charge: The Use of Water in Animal Slaughter and Processing
2
3 Background
4
5 Current FSIS regulations on the use of water during the processing of meat and poultry products
6 were last updated in the 1990s and may not account for the most recent technologies or
7 alternatives to water use. Water requirements for establishments slaughtering and processing
8 meat and poultry products are covered in the sanitation regulations in 9 CFR 416.2(g)(1), (2),
9 (3), (4), (5) and (6). The water used in food processing must comply with 40 CFR 141, the
10 National Primary Drinking Water regulations, if a municipal water supply is used. If a private
11 well is used, food processors must make documentation certifying the water’s potability
12 available to FSIS. Regulation 9 CFR 416.2(g)(4) limits the use of reconditioned water and may
13 not reflect current technological capabilities of water treatment. Climate change is challenging
14 the food industry’s access to clean and inexpensive water. The frequency, severity, duration, and
15 location of weather and climate phenomena (i.e., rising temperatures, flooding rains, and
16 droughts) are changing, which will continue to impact the food industry’s ability to produce safe
17 food. It is essential that regulatory agencies assess these changes and evaluate current regulatory
18 requirements associated with water use. They must also be able to provide alternatives to current
19 water consumption practices that allow industry to use less and recycle more water through
20 developing criteria on the appropriate uses of water sources in the processing of food.
21
22 Executive Summary
23
24 Water is an essential part of food animal processing, and current processing practices use large
25 volumes of water. Due to climate change, the food industry’s access to clean and inexpensive
26 water is increasingly a challenge. The Food Safety and Inspection Service (FSIS) seeks
27 evaluation by the National Advisory Committee on Microbiological Criteria for Food
28 (NACMCF) to facilitate the safe reuse of sources of water in order to reduce water consumption.
29
30
3
31 Charge Questions to the Committee and Committee Responses
32
33 FSIS requests guidance from the NACMCF to address alternatives to current water usage
34 practices, guidelines, and regulations for FSIS-regulated products to help clarify the following
35 issues:
36
37 Charge Question #1
38
39 What are the current water usage practices for slaughterhouses and processors? At which steps
40 might water conservation or alternative water sources be feasible?
41
42 Summary/Recommendations
43
44 • There is a large variability, such as processing practices for each animal, practices within the
45 same animal species, etc., in the application of water in food-animal processing.
46 • There are a limited number of publications on water use by species. The industry may have
47 some information that is not publicly available.
48 • Important gaps are the lack of information for pork and channel catfish processing.
49 • Water management strategies should include water conservation practices, which are low-
50 cost practices that may result in important reductions in water usage.
51 • The 2020 COVID-19 pandemic may have a large impact on the increase of water usage,
52 specifically related to the implementation of more stringent cleaning and sanitation practices
53 in meat and poultry processing establishments.
54 • There should be more collaborations among stakeholders (e.g., industry, academia,
55 government) to collect missing information on water usage and opportunities for reuse.
56
58
59 What are the available technological strategies for water reuse, recycling, reconditioning, and
60 reclamation, and how might FSIS-regulated facilities employ them? Is a fully closed water
61 system reasonable as a goal?
62
4
64
65 • Many factors influence the type of wastewater treatment methods that an establishment can
66 implement, including the local cost of water and the cost of the technology.
67 • There are already examples of water reuse in a counterflow direction to the movement of
68 product, such as the counterflow scalders and chillers used for the processing of chickens.
69 • Water conservation, based on judicious use of water changes in behavior, is an important
70 starting point to reduce the overall water usage.
71 • A complete understanding of energy use and plant infrastructure limitations is necessary to
72 effectively understand all opportunities for water conservation and recycling.
73
75
76 Water contaminants can be microbiological, chemical/toxicological, physical, and nutrient in
77 nature. Identify these contaminants and how their presence and concentrations in potable water
78 (municipal and well-sourced) compare to those found in water treated using the reuse, recycling,
79 reconditioning, and reclamation technologies identified in (2) above. Identify the risks posed by
80 these contaminants for various steps in food production and processing.
81
83
84 • Characterization of microbial and chemical contaminants in water is a very large topic that
85 requires extensive work.
86 • There are quality standards for potable water but not for the recycled water from different
87 processing states, and different water treatment systems.
88 • Different treatments may deal with different contaminants. Thus, a comparison of potable
89 water versus reused/recycle/reconditioned water is not easy to address.
90 • As we move to fit-for-purpose water recycling and usage, quality standards may need to be
91 developed for each application and recycling system.
92
5
94
95 How do residual contaminants in water used for animal production, slaughter, and processing
96 affect product quality and safety? What are the quality implications and public health risks
97 associated with contaminants at levels anticipated for reconditioned water? How might FSIS and
98 industry best assess those implications and risks? How do residual contaminants in water affect
99 the functions of various materials added to water used in all stages of food production and
100 processing, such as feeds, medicines, and antimicrobials? For example, consider the effects of
101 trace pharmaceuticals on animal husbandry, and the effects of iron and “hard water” on
102 phosphate-based interventions.
103
105
106 • The distinction of two water quality standards, one for water that has direct or indirect
107 contact with food and one for water that has no contact with food, best assures safety.
108 • FSIS and industry can use a fit-for-purpose risk assessment approach to assess public health
109 risks from water reuse in food contact applications that do not already require potable water
110 quality and make the risk assessment adaptable to the specific food and use situations.
111 • Reused water in animal processing should be evaluated to ensure that the finished products
112 do not exhibit an increase (relative to current water usage practices) in the health risks
113 associated with these products.
114 • A uniform standard for, and federal regulation of, the quality of reused/recycled water in
115 FSIS-regulated facilities is needed. Currently, local authorities using highly variable criteria
116 determine both the water standard and regulation.
117
119
120 What are the best ways to assure and/or monitor the quality and safety of alternatively sourced
121 water used in FSIS-regulated operations?
122
124
6
125 • There are physical, chemical, and microbiological parameters that have been traditionally
126 monitored to assess water quality.
127 • Standard water analysis methods are available, well-developed, and reliable. Initial
128 monitoring of alternatively sourced water should be extensive, while ongoing performance
129 monitoring should be in real-time and focus on measuring indicators (refer to Glossary).
130 Water for non-food contact uses will require monitoring of fewer parameters.
131 • The set of quality parameters to be tested, and the frequency, should be developed for each
132 technology and application based on the contaminants of concern and those that the
133 technology will reduce/remove.
134 • This set of quality parameters could include indicators of water quality for each food animal
135 species, for different areas in processing and for the processing areas where reprocessed
136 water will be used.
137
139
140 Are there special considerations for foods that are produced entirely within water (e.g., fish), and
141 if so, what are they?
142
144
145 • Maintaining good water condition in fishponds is essential to control fish diseases and to
146 provide adequate production of channel catfish.
147 • Some water conservation strategies have been published for fish processing establishments;
148 however, economic and other incentives to incorporate conservation practices or recycling
149 technologies do not exist.
150
151
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153
154 Flooding can contaminate animals and water sources with human sewage and farm waste. What
155 precautions should establishments take when floodwater or runoff affects a food or water source,
156 or a processing area?
157
159
160 • Companies should develop emergency programs to manage natural disasters, such as
161 flooding.
162 • There are several national and state guidelines that can be reviewed for the organization of
163 these emergency programs.
164
166
167 What technologies are appropriate for the replacement of liquid water in food production and
168 food processing areas (e.g., foam, mist, or dry chemicals)?
169
171
172 • Conducting a review of cleaning and sanitation and other manufacturing practices and the
173 use of alternative technologies, such as air chilling instead of water chilling, helps in the
174 identification of areas in which changes could contribute to an overall reduction of water use
175 in a processing establishment.
176 • Newer technologies (e.g., ozone generators and ultraviolet treatments, surface coatings with
177 sustained antimicrobial properties) are being approved by the EPA for specific sanitation
178 practices and may provide viable alternatives to reduce water usage during the cleaning and
179 sanitizing practices in animal food establishments.
180
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181 Responses to Charge Question #1
182
183 What are the current water usage practices for slaughterhouses and processors? At which
184 steps might water conservation or alternative water sources be feasible?
185
186 There is a large variability in the application of water in food animal processing. This variability
187 includes differences in the processing practices for each animal species (beef, pork, poultry and
188 channel catfish), and variations within the practices employed within the same animal species.
189 Other factors that affect water usage practices include the available and implemented
190 technologies at the establishments, the equipment and practices in place, education and training
191 on water conservation (refer to Glossary), and the actual cost-benefit of water
192 conservation/recycling/reuse (refer to Glossary) for each establishment. However, there is
193 limited information on the exact water use at each of the different processing steps, and for the
194 different food animal establishments in the USA (Compton et al., 2018; Meneses et al., 2017).
195 There is also limited information on the cost-benefit of each of the available water
196 conservation/recycling/reuse technologies.
197
198 In general, meat processing may account for up to 24% of freshwater consumption in the food
199 and beverage industries, while seafood accounts for approximately 2% (Bustillo-Lecompte and
200 Mehrvar, 2015). A report from Australia estimated that the water usage in beef slaughter
201 establishments varied from 3.8 to 17.9 kiloliters per ton of carcass weight produced (Warnecke et
202 al., 2008).
203
204 Table 1-1 describes the estimated amounts of water used during the processing of broiler
205 chicken, beef and turkeys. Although there are several reports on the use of water in
206 establishments processing broiler chickens and beef, there is less information about
207 establishments processing turkeys, pork and channel catfish. Most of the published studies about
208 water use in beef are from countries other than the USA.
209
210
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211 Water Conservation
212
213 The potential costs-benefits for water reuse or recycling projects may result in an increased
214 efficiency by the establishment, with energy savings and more efficient use of antimicrobial
215 applications. A complete understanding of energy cost and plant infrastructure limitations is
216 important to effectively understand all opportunities for water conservation and recycling.
217
218 The water usage in broiler processing is described in Table 1-2. Poultry harvest facilities rely
219 primarily on water to drop the temperature of the carcasses post-evisceration and to deliver
220 antimicrobials to control bacterial pathogens. For broiler chickens and turkeys, water chillers are
221 as large as 200,000 gallons. The major water usage occurs in the areas from evisceration to
222 carcass chilling. In each of these areas, there are opportunities for water conservation. In some
223 cases, the industry has reused water (refer to Glossary)from the end of the chill tanks to feed the
224 scalding tanks (Amorim et al., 2007; Blevins, 2020; Matsumura and Mierzwa, 2008; Northcutt
225 and Jones, 2004; Russell, 2013).
226
227 In a study conducted in a broiler processing plant in Brazil (Amorim et al., 2007) with a water
228 supply consisting of 99.5% deep water wells and 0.5% public water supply system, the proposals
229 for water consumption reduction included:
230
231 • Reusing effluent from cleaning of transport cages (after removing coarse solids) would
232 result in reductions of:
233 o 12% of drinking water consumed
234 o 1% of the effluent generated
235 • Reusing effluents generated by the cooling towers and in the de-freeze of cooling
236 tunnel/storage chambers; 7.5% and 1.4% of wastewater (refer to Glossary) generated,
237 respectively; to wash live poultry receiving and unloading yards would result in
238 reductions of:
239 o 91% of drinking water consumed
240 o 7% of the slaughterhouse's overall water consumption
241 o 9% of the effluent generated
10
242 • Reusing effluent from the final rinsing of the slaughterhouse cleaning process to pre-
243 wash the by-product room would result in a 4% reduction in overall water consumption.
244 • Using all three of the proposals listed above would result in:
245 o A reduction of about 12% of the water taken from the deep water well
246 o A reduction of approximately 10% in the effluent generated
247 o A savings of approximately $6,500 (US) per year in wastewater treatment costs
248
249 These authors also highlighted that the incorporation of automatic, pressure-activated closing
250 water taps could save approximately 40% of water compared to conventional taps, and that
251 incorporating an infrared device for opening and closing of taps would save an additional 30% of
252 water usage (Amorim et al., 2007).
253
254 Table 1-3 describes the estimated water usage in a beef processing facility. A review from an
255 Australian beef processing facility highlights that water conservation can save up to 10% of the
256 water usage in a small town (Pype et al., 2016). Water reuse, which is described by these authors
257 as the “reuse of one process waste stream to the same or another process with or without pre-
258 treatment,” could save up to 15% of a town’s water usage. The publication also highlights that in
259 small towns, the recycling of non-potable water can save up to 40% of town water use, with a
260 recovery on the investment within 6 to10 years. The recycling of potable water (refer to
261 Glossary) can save up to 70% of town water use, with a recovery on the investment of about 10
262 years. The calculated payback time of implementing these practices ranged from immediate to up
263 to three years (Pype et al., 2016). Yet, some water reuse technologies may not be practical or
264 economically feasible for small slaughter establishments.
265
266 In pork and beef harvest establishments, carcasses are chilled primarily by air chilling. However,
267 water spray chill systems are also employed throughout the pork and beef industries. Because the
268 skin is not removed in the initial steps in pork processing, various methods of carcass scalding
269 are used to remove hair follicles and wash the carcass. This can be done via large scald tanks or
270 can be accomplished using other technologies, such as steam through vertical scalding units.
271
11
272 There is no publicly available data on the use of water in channel catfish processing. There are
273 advantages in improving water management and there are several companies providing water
274 conservation consulting services to the food industry. Most of these companies collect
275 background information on water usage in an animal food processing establishment by
276 performing water audits, which can help create a water management plan to better understand the
277 total water consumption and discharge, and identify inefficient or unnecessary uses, such as taps
278 that are left on overnight. By applying a checklist of good practices, and systematically metering
279 and tracking the volume of water used in a facility, an establishment can help to identify areas
280 for potential water conservation (Timmermans, 2014). Table 1-4 shows the areas of a processing
281 environment where there is potential for conservation and savings.
282
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284
285 What are the available technological strategies for water reuse, recycling, reconditioning,
286 and reclamation, and how might FSIS-regulated facilities employ them? Is a fully closed
287 water system reasonable as a goal?
288
289 Factors that Determine the Choice of Technology
290
291 Water is a necessary component for meat production and meat processing. Water serves an
292 important role in product formulations, processing, sanitation, and food safety. However,
293 considerations for technology used for wastewater treatment methods and the ability to reuse
294 and/or recycle is plant- specific. These abilities are based upon the primary function and the
295 infrastructure of the plant, the efficiency and cost of implementing these strategies, and
296 regulatory requirements for both water end use and effluent.
297
298 Animal Harvest and Raw Processing
299
300 Water is vital in providing safe and wholesome food products of animal origin. The recognition
301 of food safety and the removal of pathogens during meat processing has required the use of
302 surface antimicrobials to be used throughout the harvest process. These surface antimicrobials
303 are often diluted processing aids that are effective against eliminating pathogens, but also have
304 the least organoleptic effect on the quality of the meat. The reliance and need for these surface
305 antimicrobials will continue as standards for food safety increase.
306
307 A few opportunities for water reuse present themselves in the harvest process across all animal
308 protein establishments. In general, water that is the cleanest and least contaminated should be
309 used after the evisceration process. However, considerations for water quality, as it relates to
310 food safety, will need to be evaluated to determine opportunities for reuse. An example of a
311 potential scheme for the utilization of reused water in a turkey harvest operation could be the use
312 of water in a counter-flow direction to the movement of product:
313
13
314 Chiller Water  Final Bird Wash  First Bird Wash  Feather Wash  Cage wash
315
316 Larger scale capital projects would need to be evaluated on their merits and overall cost. An
317 example of water usage reduction would be a pork processing plant considering a change from
318 water spray chilling carcasses to utilization of a mechanical process of chilling, such as blast
319 chilling. Evaluation for the water usage from spray chilling would need to be assessed against the
320 increased overall energy usage from blast chilling to determine if there is a net environmental
321 benefit, an assessment for a potential opportunity to reuse the water used in a different
322 application further upstream in the process, as well as a financial net present value gain by
323 making the change.
324
325 Ready-to-Eat and Further Processing
326
327 The water usage in further processing facilities should also be considered. Like harvest and raw
328 processing facilities, water is used for sanitation, to deliver ingredients in formulation, and to
329 improve food safety. Many of the ingredients delivered with water are vital to the functionality,
330 identity, palatability, and safety of the product. Functional ingredients such as salt, sugar, sodium
331 nitrite, and antimicrobials are carried into the product via a brine. Thus, potable water is the
332 minimum standard of acceptance for use in formulations.
333
334 Sanitation and Plant Design
335
336 Wet cleaning (refer to Glossary) sanitation is also widely employed throughout the meat
337 processing industry. Reduction of water use may not be practical because of its importance in
338 cleaning and sanitizing processing lines. However, opportunities for water reuse water in a
339 counter flow direction from the movement of product could be employed. An example of this
340 would be using water from the final bird wash upstream in the process, such as in the feather
341 wash or cage wash in the trailers used to transport the live birds. Due to the nature of the
342 processes and the types of contaminants present, there are fewer opportunities for dry sanitation
343 in the meat processing establishments. Because meat is an excellent growth medium for many
344 bacteria (including pathogens), wet sanitation is also required to provide processing “breaks” in
14
345 production and a sanitation schedule that reduces pathogens and spoilage bacteria. Cleaning and
346 sanitizing protocols also limit the extent of the compromised product, should the product become
347 contaminated with a known pathogen that results in a recall. Extended product runs to reduce the
348 frequency of sanitation are often product specific and need to be monitored and verified to show
349 effectiveness with respect to food safety requirements (Anonymous, 1999).
350
351 Besides water usage implications, there are other potential meat quality, food safety, and cost
352 implications that need to be considered if changes to water usage practices are considered. Many
353 of the processing plants in the USA were built before many environmental conservation practices
354 were envisioned and included within the building design. Thus, electrical, plumbing, and sewage
355 requirements may present cost barriers that are difficult to overcome. Also, the ability to utilize
356 reused and/or recycled water (refer to Glossary)may require space that may not be available in
357 older processing plants without major renovation or construction of the facility. Inline treatment
358 systems and the need for holding tanks may limit a plant’s ability to utilize reused or recycled
359 water in the current footprint of the plant.
360
361 Existing New Technologies for Wastewater
362
363 The US EPA has established Effluent Guidelines (US EPA, 2002) to comply with national
364 standards for industrial wastewater discharges to surface waters and publicly owned treatment
365 works (e.g., municipal sewage treatment plants). The Effluent Guidelines are issued for different
366 industrial sectors under Title III of the Clean Water Act. The standards are technology-based
367 (i.e., they are based on the performance of treatment and control technologies), and not risk-
368 based, or based on impact studies. The standards for wastewater discharges from meat and
369 poultry processing are codified under Title 40 of the Code of Federal Regulations (CFR) Part
370 432 (US EPA, 2002), and include the discharge limits for several parameters, or indices,
371 including pH, fecal coliform (refer to Glossary), total recoverable oil and grease, 5-day
372 biochemical oxygen demand (BOD5; refer to Glossary), and total suspended solids. Some of
373 these indices provide information on the degree of organic pollution of the water.
374
15
375 Bustillo-Lecompte and Mehrvar (2015) reviewed different slaughter wastewater treatment
376 methods. Following is a brief discussion of those different methods:
377
378 Land application: Land application refers to the direct application of biodegradable materials to
379 soil which can help increase the nutrient content of the soil. One significant advantage of this
380 process is the recovery of by-products from slaughter wastewater which can be used as an
381 alternative source of fertilizer. The land application process can also improve the structure of the
382 receiving soil. One limitation of land application is that the process is dependent on factors like
383 temperature and weather conditions. Hence, land application finds limited use in countries that
384 experience very low temperatures during the winter season. Some other limitations of land
385 application include potential surface water pollution, presence of persistent pathogens, and off-
386 odors (San Jose, 2004; Mittal, 2004; Avery et al., 2005; Kiepper, 2001).
387
388 Physicochemical treatment: In the process, slaughterhouse wastewater (SWW) is separated into
389 different components (primarily solids and liquids) using different types of methods (Al-Mutairi
390 et al., 2008; De Nardi et al., 2011): (a) dissolved air filtration (DAF), (b) coagulation and
391 flocculation, (c) electrocoagulation, and (d) membrane technology.
392
393 • DAF: These systems utilize air to separate liquids and solids in slaughter wastewater. The
394 separation of solids and liquids is achieved via introduction of air from the bottom of the
395 holding vessel. As a result, low density products like fat, grease, and light solids will migrate
396 to the top of the surface forming a “sludge blanket”. This sludge blanket will then
397 subsequently be removed. Advantages of this system results in improved chemical oxygen
398 demand (COD; refer to Glossary) and BOD. In addition, this system is also successful in
399 removal of nutrients from SWW. Some limitations noted by previous studies include a
400 regular malfunctioning of the system and poor total solids removal (Al-Mutairi et al., 2008;
401 De Nardi et al., 2011).
402 • Coagulation and flocculation: This process involves the addition of coagulants such as
403 aluminum sulfate, ferric chloride, or ferric sulfate to treat SWW. Studies showed that these
404 systems can significantly reduce the total phosphorous, total nitrogen and COD during SWW
16
405 treatments using poly-aluminum chloride as reagents (Núnez et al., 1999; Aguilar et al.,
406 2002).
407 • Electrocoagulation: Electrocoagulation is a cost-effective technology that has been

408 demonstrated to be successful in separating solid and liquid waste in SWW systems. In
409 addition, the system was proven to be effective in removing organics, nutrients, heavy
410 metals, and even pathogens from SWW without the involvement of chemicals (Kobya et al.,
411 2006; Emamjomeh and Sivakumar, 2009)
412 • Membrane Technology: Membrane technology, which includes technologies such as

413 reverse osmosis, nanofiltration, ultrafiltration, and microfiltration, is very effective in
414 removing particulates, colloids, and macromolecules based on pore size. Some limitations of
415 this process include (a) a reliance on additional conventional technology to efficiently
416 remove nutrients; and (b) the potential to cause fouling due to the highly concentrated SWW
417 feeding streams (Bustillo-Lecompte and Mehrvar, 2015; Almandoz et al., 2015).
418
419 Biological treatment: Biological treatment involves treating SWW systems with
420 microorganisms for the purpose of removing organics. There are two main types of biological
421 treatments described in literature: anaerobic and aerobic systems (Bustillo-Lecompte and
422 Mehrvar, 2015; Martínez et al., 1995; Mittal, 2006; Masse and Masse, 2000).
423
424 • Anaerobic Treatment: It is commonly perceived that anaerobic systems are less complex to
425 operate compared to aerobic systems, since they do not require complex equipment and
426 constant aeration. Bacteria metabolize organic compounds and produce products like carbon
427 dioxide and methane during the anaerobic digestion process. There are several advantages to
428 using anaerobic treatment systems: high COD removal; low sludge production compared to
429 those of aerobic systems; and less energy requirements with potential nutrient and biogas.
430 One of the limitations of anaerobic treatment is it may produce effluents that do not comply
431 with current discharge limits and standards. Specifically, when SWW systems are subjected
432 to anaerobic treatments, stabilization of organic compounds may not be achieved owing to
433 the organic strength of SWW.
17
434 • Aerobic treatment: In aerobic systems, bacteria metabolize organic compounds in the
435 presence of oxygen to facilitate removal of organic compounds. The strength of SWW
436 becomes a determining factor in understanding the amount of oxygen required during the
437 treatment of SWW systems. Typically, aerobic treatment is used following the treatment of
438 organic compounds using a physicochemical treatment. In other words, it may serve as a
439 final decontamination technology in the treatment of SWW. Aerobic reactors may have
440 several configurations based on the amount of nitrogen required to be removed. Typical
441 configurations for SWW aerobic treatment include activated sludge, rotating biological
442 contactors, and aerobic sequencing batch reactors (refer to Glossary).
443
444 Advanced oxidation processes (AOPs): AOPs are becoming an interesting alternative to
445 conventional treatment and a complementary treatment option, as either pretreatment or post-
446 treatment, to current biological processes. Furthermore, AOPs do not involve the application of
447 chemicals to inactivate microorganisms compared to the conventional systems (e.g., chlorination
448 that is used for water disinfection (refer to Glossary)may have the potential to produce hazardous
449 by products). As a result, AOPs have been recognized as processes that can offer advanced
450 degradation, water reuse, and pollution control, thus being positioned as an effective
451 complementary treatment. Several types of advanced oxidation process systems have been
452 described in the literature, including (but not limited to): ozonation, gamma radiation, and an
453 ultraviolet light/hydrogen peroxide application (Tabrizi and Mehrvar, 2004; Mehrvar and
454 Venhuis, 2005; Venhuis and Mehrvar, 2005; Mehrvar and Tabrizi, 2006; Bustillo-Lecompte and
455 Mehrvar, 2015).
456
457 Feasibility of A Fully Closed System
458
459 Establishments simply cannot operate without water. There are some system-wide reasons to
460 recycle water:
461
462 • Inherent energy cost: The cost of getting water out of the ground (or other sources), treat it
463 to potable standards, transport it to a facility, and then properly dispose of the wastewater by
464 treating to effluent standards and discharging back to the environment.
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465 • Competition for available water: As water becomes scarce, companies, especially those
466 located in proximity to or in metropolitan areas, will have to compete with municipalities.
467 • Social responsibilities: With increased attention to sustainability, the industry will want to
468 ensure that their water use is judicious.
469
470 Once companies consider all the above and other issues that may affect their access to water,
471 they will begin to recognize the significance of the business security that water recycling will
472 bring to their operation and realize the importance of this financial investment.
473
474 1. Obstacles to water recycling:
475 a. Outdated policies
476 b. Lack of national standards, with current regulations under the jurisdictions of states
477 and counties. Federal policies may be needed to increase consistency of water
478 recycling in all 50 states.
479
480 Establishment: Harmony Beef, Calgary Alberta Canada
481
482 Water Recycling System Manufacturer: Delco Water, Saskatoon, SK, S7P 0A6
483 (https://www.delco-water.com/delco-water-projects/harmony-beef/)
484
485 Storyline: A plant which was shut down for seven years was purchased, renovated and when the
486 time came to go on-line, the plant owners were told that their water allotment had been allocated
487 to a shopping mall. The owners had to find a solution and they focus on water recycling system.
488 After extensive world-wide search, they settle on a system designed and installed by Sapphire.
489 They are the first food processing plant in North America to reprocess their water. They recycle
490 all, except those of human waste stream, process water. Better than 90% of their daily water
491 needs are recycled water. The final discharge to sewer is only 7% of the process water volume,
492 with the rest lost to evaporation (Rich Vesta, Owner and Operator of Harmony Beef, Alberta,
493 Canada, Personal communications).
494
495 The process: They system is a continuous system with the flow rate of 13.9 L/second
19
496 1. Mechanical Treatment: Water flows through drum screen with 1 mm slot openings to remove
497 coarse particles and large suspended solids.
498 2. Primary Treatment: inline analyzer to adjust the pH to 5.8-6.7 and then to Dissolved Air
499 Flotation (DAF; refer to Glossary) – This stage removes medium to fine size particles, grit,
500 fat, oil and grease. The removal is achieved by dissolving air in the water or wastewater
501 under pressure and then releasing the air at atmospheric pressure in a flotation tank basin.
502 The released air forms tiny bubbles which adhere to the suspended matter causing the
503 suspended matter to float to the surface of the water where it may then be removed by a
504 skimming device.
505 3. Secondary Treatment: Pumped to another tank for moving bed biofilm reactor (MBBR, refer
506 to Glossary), which is an attached growth biological treatment process. Prior to MBBR
507 inline analyzers adjust the pH to 6.8-7.2. It is an aerobic digester system
508 4. Tertiary Filtration: membrane ultrafiltration is used to remove emulsified oils, small,
509 suspended solids, and larger molecules from the flow.
510 5. Polishing: Water flows through dual Reverse Osmosis (RO) membrane to remove total
511 dissolved solids, pesticides, cysts, bacteria, and viruses. Utilizing a two-pass design
512 minimizes wastewater disposal from the treatment process.
513 6. Disinfection: U.V. filtration and then chlorinated to 1-2%
514 7. Pump to 500,000-gallon tank ready for use.
515 8. Sludge treatment – Finally, the sludge moves through a dewatering process to reduce sludge
516 volume by 60% to 70%.
517
518 Water Quality: Actual data from Certificate of Analysis (CoA) issued by Element (Calgary
519 Canada) for Harmony Beef. Examination of a number of such CoAs indicates very little
520 variability.
521
522 1. Microbial Analysis
523 a. Coliforms - <1.0 CFU/ml (below the detection limit of the method)
524 b. E. coli - <1.0 CFU/ml (below the detection limit of the method)
525 2. Physical and Aggregate: meets or exceeds standards
526 3. Chemistry
20
527 a. pH 9.1
528 b. Electrical conductivity 392 microS/cm
529 c. Dissolved Calcium 1.1 mg/L
530 d. Dissolved Magnesium 0.3 ml/L
531 e. Dissolved Sodium 81.9 mg/L
532 f. Dissolved Potassium 5.8 mg/L
533 g. Dissolved Iron 0.01 mg/L
534 h. Dissolved Manganese 0.008 mg/L
535 i. Dissolved Chloride 37.6 mg/L
536 j. Fluoride <0.05 mg/L
537 k. Nitrate – N 0.03 mg/L
538 l. Nitrite - N 0.012 mg/L
539 m. Nitrate and Nitrite 0.04 mg/L
540 n. Dissolved Sulfate <0.9 mg/L
541 o. Hydroxide <5 mg/L
542 p. Carbonate 39 m/L
543 q. Bicarbonate 100 mg/L
544
545 Advantages:
546 1. No reliance on municipalities for water
547 2. No competition for human for water
548 3. Far better quality of water than municipal or well water
549 4. 3-4 years pay back
550 5. No need to lagoons
551 6. No incoming water or wastewater fees
552
21
554
555 Water contaminants can be microbiological, chemical/toxicological, and nutrient in nature.
556 Identify these contaminants and how their presence and concentrations in potable water
557 (municipal and well-sourced) compare to those found in water treated using the reuse,
558 recycling, reconditioning, and reclamation technologies identified in (2) above. Identify the
559 risks posed by these contaminants for various steps in food production and processing.
560
561 This specific Charge question was found to be a large topic to cover, with extensive variations
562 due to the many different factors, including:
563
564 • Animal species processed
565 • Stage of processing at which water is used
566 • Contaminant under study
567 • Sensitivity of the methodology to detect the target contaminant
568 • System used to produce reused/recycled/reconditioned water (refer to Glossary)
569
570 There is limited information detailing all the potential contaminants (refer to Glossary), mainly
571 chemical and biological, that can be present in the water used during processing. Yet, it could be
572 assumed that all known contaminants of public health concern that have been identified by
573 species (e.g., Campylobacter spp. in broiler chickens, or Escherichia coli O157:H7 in beef)
574 could end up in processed water in an establishment processing that species. It is also important
575 to remember that water potability relates to drinking water standards and is done mainly by
576 testing for chemicals and coliform indicator bacteria, not by testing for pathogenic bacteria per
577 se.
578
579 Studies of drinking and recreational water have generated a large volume of information on risk-
580 based water quality thresholds for different water quality indicators using quantitative microbial
581 risk assessment (refer to Glossary). The presence of fecal indicator bacteria (FIB, fecal coliform
582 or enterococci) usually correlates with adverse health effects and are used as water quality
583 criteria in regulations aimed at protecting public health (US EPA, 2012a). Yet, human fecal
22
584 indicator bacteria, not just all FIBs, are now accepted as the most important indicator of ambient
585 water contamination (Boehm and Soller, 2020). We do not have similar information on the most
586 appropriate indicators for water recycling in food animal processing establishments (refer to
587 answers for Charge Question #5).
588
589 Nature of the Contaminants
590
591 Water used in the processing of animal protein establishments contain high amounts of organic
592 matter, pathogenic and non-pathogenic microorganisms, residual chemicals from cleaning and
593 sanitizing activities (Bustillo-Lecompte and Mehrvar, 2015; Debik and Coskun, 2009; Masse and
594 Masse, 2000). An essential aspect of food safety efforts in meat, poultry, channel catfish and egg
595 products are the monitoring and control of chemical residues that may result from the use of
596 animal drugs and pesticides, or from incidents involving environmental contaminants. The
597 chemical contaminants coming with the live animal raised with proper husbandry practices
598 should not bring any public health concern. These contaminants include chemical compounds
599 added to the animal during production, such as growth promoters and antibiotics to control
600 animal disease.
601
602 There are specific regulations on the use and application of drugs in food production animals.
603 These regulations establish withdrawal times for chemical compounds that need time to clear up
604 from the animal and be at levels that do not represent human health concerns. The U.S.
605 Department of Agriculture’s Food Safety and Inspection Service (USDA FSIS) administers the
606 U.S. National Residue Program (NRP) for meat, poultry, and egg products. The NRP is an
607 interagency program designed to identify, prioritize, and analyze veterinary drugs, pesticides,
608 and environmental contaminants in meat, poultry, and egg products. FSIS partners with the Food
609 and Drug Administration (FDA) and the Environmental Protection Agency (EPA) as the primary
610 Federal agencies that manage the NRP. The FDA, under the Federal Food, Drug, and Cosmetic
611 Act (FFDCA), establishes tolerances for veterinary drugs and action levels for food additives and
612 environmental contaminants and reviews violative residues reported to FDA by USDA FSIS for
613 risk-based inspection and compliance follow-up. The EPA, under the FFDCA, the Federal
614 Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the Toxic Substances Control Act,
23
615 establishes tolerances for registered pesticides. Title 21 CFR includes tolerance levels established
616 by FDA, and Title 40 CFR includes tolerance levels established by EPA.
617
618 FSIS publishes NRP Data (traditionally known as the Red Book) each year to summarize the
619 results of testing meat, poultry, and egg products for chemical residues and contaminants of
620 public health concern. When testing for residues in food animal tissues, test results reported by
621 FSIS laboratories are compared to a quantitative acceptable level (i.e., tolerance or action level)
622 to verify that the meat, poultry, and egg products tested are safe and wholesome and do not
623 contain levels of a chemical that would render the product adulterated.
624
625 The NRP domestic sampling program is comprised of two correlated programs: the scheduled
626 sampling program and the inspector-generated sampling program. Under the inspector-generated
627 sampling plan, the number of samples screened and collected has remained the same (FY 2016 -
628 2019), at approximately 174,000 samples screened per year. The violation rate has remained
629 below 0.4% and has declined since 2016. The predominant violative residues in the samples
630 were antibiotics, mainly ceftiofur, penicillin, and sulfadimethoxine, which account for 30%,
631 23%, and 9.7% of total violative residues, respectively. Of the violations reported, 85% were
632 attributed to cattle; dairy cows accounted for 71%, and bob veal for 14%. In samples from swine
633 slaughter (market swine, sows, roaster swine, boar swine, and feral swine), there were only 8
634 violative samples, which represented 0.03% of the swine samples (USDA FSIS, 2019). The
635 drugs in violations are mainly antibiotics found at higher than allowable levels. Thus, unless we
636 consider the potential adverse reaction to an antibiotic (e.g., penicillin), these antibiotics are not
637 per se a direct human health hazard.
638
639 Chemical Contaminants, Including Chemical Sanitizers
640
641 There is a potential for chemicals for sanitation practices to contaminate water used in animal
642 food processing plants, but there is no information on the impact of the accumulation of these
643 residual chemical sanitizers (refer to Glossary), or their by-products, on the efficacy of the
644 recycling technologies. In addition, there is limited information on the cost to remove all
645 sanitizer from contaminated water in an animal food processing establishment. It is not clear if
24
646 interaction among different chemical compounds may bring challenges with water recycling
647 systems. Thus, this is an area where more information is needed.
648
649 The chemical compounds used to control pathogens during the processing of food animals, and
650 that have contact with food, have all received approval by FDA as generally recognized as safe
651 (GRAS; refer to Glossary) or as a secondary direct food additive permitted in food for human
652 consumption (Anonymous, 1977), more specifically as an “antimicrobial agent” (refer to
653 Glossary). These antimicrobial agents are considered processing aids with temporary technical
654 effect in the treated food and are ordinarily removed or not present in the final food. Thus, any
655 residuals that may be carried over to the final product are not expected to have any effect on the
656 final product. Through the shared ingredient approval process by the two agencies, USDA FSIS
657 makes judgments on a case-by-case basis using FDA’s approval of a compound to determine
658 whether a substance is a processing aid, and can be used as an antimicrobial agent, or is an
659 ingredient of a food. While USDA FSIS determines the suitability and effectiveness for the
660 intended purpose of use, the Agency also ensures that the conditions of use do not result in an
661 adulterated product. Once the suitability and safety of a compound has been determined, the
662 substance is added to FSIS Directive 7120.1 (USDA FSIS 2021a). USDA FSIS also maintains a
663 list of Safe and Suitable Ingredients that is periodically updated (USDA FSIS 2021b). Although
664 there is no information on the residues of “antimicrobial agents” (GRAS or secondary direct food
665 additives) in processing water, the probability of any accumulation of these substances in their
666 active forms in water is low.
667
668 Under regulations codified as Title 9 CFR Part 416 Sanitation, establishments under the
669 jurisdiction of USDA FSIS are required to implement and monitor written Sanitation Standard
670 Operating Procedures (Sanitation SOPs) and maintain daily records to document the
671 implementation and monitoring of the Sanitation SOPs and any corrective action taken. Under 9
672 CFR 416.4, the regulations require that:
673
674 §416.4(c) Cleaning compounds, sanitizing agents, processing aids, and other chemicals
675 used by an establishment must be safe and effective under the conditions of use. Such
676 chemicals must be used, handled, and stored in a manner that will not adulterate product
25
677 or create insanitary conditions. Documentation substantiating the safety of a chemical's
678 use in a food processing environment must be available to FSIS inspection program
679 employees for review.
680
681 Companies selling cleaning and sanitizing agents must sell only compounds that have been
682 approved for these activities and are registered as antimicrobial pesticides with EPA under
683 FIFRA.
684
685 Within the food commodities under USDA FSIS, processed eggs and Siluriforme fish are
686 considered allergens. Therefore, establishments that need to reduce these allergenic proteins
687 from surfaces to avoid cross-contact will also have to establish cleaning and sanitation protocols
688 that are specific for these circumstances.
689
690 Biological Contaminants
691
692 Biological contaminates are important contaminants present in water used in animal food
693 establishments. Yet, the large variation in the type and amount of contamination in an
694 establishment makes it difficult to include all the potential hazards. Factors such as the origin of
695 the biological hazard (human, animal, environment), the potential for survival, and the difficulty
696 for removal play a role in the degree of contamination of wastewater and therefore each animal
697 food establishment is unique. Testing for all potential biological hazards is not practical and the
698 collection of information with a structured quality assessment of the wastewater and recovered
699 water has been described as an important initial step before implementing reconditioning (refer
700 to Glossary) treatments (Meneses et al., 2017).
701
702 At the time this report is written, the world is undergoing the COVID-19 pandemic and many
703 food processing establishments are using more stringent cleaning and sanitation protocols and, in
704 some cases, are disinfecting surfaces to reduce the spread of SARS-CoV-2. Thus, processors
705 may be reducing microbial loads further than what is achieved by regular sanitizing procedures
706 due to COVID-19.
707
26
708 Contaminants at Different Processing Steps
709
710 The transformation of live animal into human food varies from species to species, but it can be
711 assumed that all the processing steps during the dressing of animal carcasses, where water
712 contacts the carcasses, will have the potential to contaminate the water with, primarily, biological
713 and chemical hazards. Once carcasses are eviscerated, washed, and the temperatures lowered,
714 there will be less water contacting the carcasses. Yet, some water is used during cutup, deboning
715 or portioning and may contain species-specific microbiological hazards.
27
717
718 How do residual contaminants in water used for animal production, slaughter, and
719 processing affect product quality and safety? What are the quality implications and public
720 health risks associated with contaminants at levels anticipated for reconditioned water?
721 How might FSIS and industry best assess those implications and risks? How do residual
722 contaminants in water affect the functions of various materials added to water used in all
723 stages of food production and processing, such as feeds, medicines, and antimicrobials? For
724 example, consider the effects of trace pharmaceuticals on animal husbandry, and the
725 effects of iron and “hard water” on phosphate-based interventions.
726
727 As shown in Table 4-1, Charge Question #4 and Charge Question #5 can be broadly framed
728 using a risk assessment framework per Codex Alimentarius guidelines (FAO/WHO, 2001).
729
730 How Residual Contaminants Affect Product Quality and Safety
731
732 Not all FSIS-regulated operations’ steps require the use of potable water. Wastewater from some
733 processes, with or without additional treatment, may meet the requirements of various, specific
734 reuse and can be safely recycled. For example, Miller et al. (1994) found that the use of
735 reconditioned and chlorinated water on swine carcasses during scalding, dehairing, and polishing
736 had no effect on the load of foodborne pathogens (including staphylococci, enteric streptococci,
737 Listeria monocytogenes, coliforms, and Aeromonas) on carcasses (Miller et al., 1994).
738
739 Water used in FSIS-regulated operations can be broadly categorized as those with direct contact,
740 indirect contact, or no contact (refer to Glossary) with product. The following gives definition
741 and examples of each:
742
743 Water with direct product contact: Water that directly contacts the product or surfaces that
744 come into direct contact with the product being processed include:
745
746 • Final rinsing of edible product that is not further processed;
28
747 • Preparation of surfaces including hooks, tables, conveyors, etc., that would have direct
748 contact with meat products or meat packaging materials;
749 • Final rinsing of clean-in-place (CIP) systems or manual cleaning systems; and
750 • Direct addition of water as an ingredient in a manufactured meat product.
751
752 Water with indirect product contact: Water inside the meat processing environment that is not
753 in direct contact with the product or product contact surfaces include:
754
755 • Environmental sanitation of non-meat product contact surfaces inside the processing
756 environment, with consideration for the risk of contamination of unprotected meat
757 product contact surfaces by aerosols or transfer of water from the non-product contact
758 surfaces; and
759 • As a diluent for cleaning and sanitation chemicals used in Cleaning-In-Place (CIP; refer
760 to Glossary) systems or manual sanitation, excluding the final CIP water rinse.
761
762 Water with no product contact: Water with the lowest risk outside of the meat processing
763 environment include:
764
765 • Boilers and cooling towers, with consideration for the risk of aerosols and transfer of
766 water into the meat processing environments; and
767 • Washing of transport vehicles, with consideration for the risk of cross-contamination
768 from containers to product packaging and then to product.
769
770 Spreading non-potable water on food (i.e., direct contact) may make the food unsafe, as this
771 water may contain pathogens and chemicals. Current regulations and guidance to industry found
772 in 9 CFR 416.2(g) and USDA FSIS’s guidance for water, ice, and solution reuse in poultry
773 mandate that water must remain free of pathogenic organisms and fecal coliform organisms and
774 that other physical, chemical, and microbiological contaminates have been reduced to prevent
775 adulteration of product (Anonymous, 1999; USDA FSIS, 1999).
776
29
777 Creating various grades of water quality is not practical. The distinction of two water qualities,
778 one that has direct or indirect contact with food and one that has no contact with food, can
779 simplify the implementation of water reconditioning (refer to Glossary) programs while assuring
780 safety. Currently, both the water standard and regulation of that standard is by local authorities
781 and is highly variable across the nation.
782
783 Quality and Public Health Implications in Reconditioned Water
784
785 The quality of alternatively sourced (se glossary) water with no direct contact with product, used
786 inside the processing plant, as well as alternatively sourced water with no product contact, used
787 outside of the processing plant, could be of a quality less than potable. Based on animal type, life
788 stage, method of raising, and amount of processing, reconditioned water may vary greatly from
789 plant to plant.
790
791 Temperature and turbidity (refer to Glossary) are the physical characteristics that impact safe
792 water usage. Water temperature affects microorganism viability, the solubility of oxygen, and
793 increases or decreases the toxicity of ammonia and other substances. Turbidity is a measure of
794 the fine sediment suspended in the water and has no inherent health effects, unless it indicates
795 inadequate filtration that may not have removed protozoa like Cryptosporidium or Giardia
796 lamblia and/or infectious viruses or bacteria. Turbidity can also interfere with disinfection and
797 may include substances that allow microbial growth.
798
799 The chemical characteristics that impact safe water usage include pH, nutrients, ammonia, and
800 dissolved oxygen and metals. Chemical water properties are often interrelated. The pH describes
801 the balance between hydrogen and hydroxide ions that can affect many other chemical
802 constituents such as the dominant form of ammonia and the solubility of metals. Water acidity or
803 alkalinity can cause corrosion (both low and high pH) or precipitation and fouling (high pH).
804 Reused water may have extreme pH values from caustic washes or regeneration of ion exchange
805 resins. Nutrient levels are usually measured as nitrate-nitrite nitrogen and total phosphorus, but
806 can be as total inorganic nitrogen, organic nitrogen, or soluble reactive phosphorus. Ammonia is
807 naturally occurring in water but can increase when nitrogen-containing organic waste and
30
808 dissolved oxygen levels increase. Dissolved metals can include arsenic, lead, mercury, iron,
809 cadmium, copper, sodium, chloride, potassium, manganese, or magnesium. Ingestion and
810 bioaccumulation in tissues can be a health risk for those who consume some metals. Mercury is
811 usually in inorganic form but can convert to toxic methylmercury in conditions of low pH, low
812 dissolved oxygen, and high dissolved organic matter.
813
814 Processing water may include the presence of residual sanitizing compounds, and their by-
815 products, used during processing. Results from the National Residue Program, described in
816 answers to Charge Question #3, highlight that agriculture and veterinary residues may not be a
817 public health concern in live animals that will be processed, if the application of agrochemicals
818 and the use of veterinary drugs follow appropriate guidelines for use. Please refer to the National
819 Residue Program under responses for Charge Question #3.
820
821 The microbiological properties that impact safe water use include pathogenic protozoa, bacteria,
822 and viruses. Organisms of concern include, but are not limited to, Campylobacter jejuni,
823 pathogenic Escherichia coli, Salmonella (including antimicrobial resistant strains of these
824 pathogenic bacteria), Cryptosporidium, spores of bacterial pathogens, Toxoplasma gondii,
825 norovirus, and helminths. Indicator organisms are often used as a marker or estimate of
826 contamination levels due to cost or inability to monitor the actual pathogen. The biological
827 indicators that highlight the potential of public health risk include the presence of fecal
828 coliforms, generic E. coli, and enterococci. In the case of parasites, such as Cryptosporidium and
829 Giardia lamblia, and viruses such as enteric viruses, the direct testing for the pathogen is used,
830 although some recent research suggest that bacteriophages can be used as indicators of fecal
831 pollution and enteric virus removal in recreational water (McMinn et al., 2017).
832
833 Australia has previously developed a national guidance document for water recycling which
834 covers both potable and non-potable end uses. The guidance document requires the development
835 of a risk assessment process for the “hazards getting through the treatment system in sufficient
836 amounts to pose a risk to human health” (Anonymous, 2008). In this document, six pathogens
837 from 52 airborne and waterborne pathogens from water reuse were identified as the pathogens of
838 concerns to address when recycling water, and some recommendations on how to ensure that the
31
839 risk assessment process, based on examining reference contaminants to represent functional
840 groups of pathogens or chemical contaminants, is compatible with the Australian Recycled
841 Water Guidelines was provided by Warnecke et al. (2008).
842
843 Facilities currently engaging in water reconditioning and reuse are reusing cleaner water for
844 areas where there are more contaminants and use only potable water for direct food contact.
845 Non-potable water is not allowed as an ingredient or to have direct contact with meat in the US.
846 Most European nations do not allow the use of recycled water in direct contact with meat (Pype
847 et al., 2016). Guidelines from the World Health Organization (WHO 2011) also highlight that
848 water from alternate sources that has direct or indirect contact with product must meet drinking
849 water guidelines. These types of regulations and guidelines have direct implications for the
850 international meat trade.
851
852 The risk of introducing hazards from the reuse of water in operations can be mitigated by
853 employing appropriate control measures, including engineering controls (e.g., filtering water on-
854 site), administrative controls (e.g., changing job tasks so one individual is not continually
855 exposed or showering out), and personal protective equipment (PPE) (e.g., gloves, mask,
856 protective eyewear, and coveralls). A risk assessment should be completed when there is a
857 change in systems, animal inputs, or water source or if there is the emergence of a previously
858 unidentified hazard. No water reuse system should be allowed to be put in place if it results in an
859 increased risk to human health. Therefore, while there are potential increased hazards with water
860 reuse, no increased risk to public health would occur with proper controls. Each plant will face
861 its own needs and challenges. Using technology coupled with well-trained individuals to
862 implement and monitor systems may protect public health while reducing environmental impacts
863 from water use in meat slaughter and processing.
864
865 Assessing Quality Implications and Risks
866
867 A report by the Food and Agricultural Organization of the United Nations (FAO) and the World
868 Health Organization (WHO) addressed the safety and quality of water used in food production
869 and processing (FAO/WHO, 2019). Although this report does not focus on water reuse, its
32
870 principles are relevant to the question addressed here. The report highlights that water quality
871 should be established in a “fit-for-purpose” basis, considering the application and context, rather
872 than using the same water quality standards across all applications. In this report, authors
873 propose the use of decision support system tools which incorporate risk assessments and the use
874 of monitoring to inform stakeholders when making decisions on water quality and reuse at steps
875 in the supply chain (FAO/WHO, 2019). A challenge in the use of risk assessments is that
876 monitoring of water quality is often based on microbial indicators, which do not correlate with
877 the presence or quantity of pathogens in water or food. This means that continuous monitoring
878 might have to also include relevant pathogens, depending on the target application of the reused
879 water.
880
881 The report also highlights the similarities in risk management approaches in safe potable water
882 and safe food, such as that both are risk- and evidence-based and need proper verification and
883 monitoring. It also points out the additional complexities in food production due to the wide
884 range of products, primary production and processing systems, microbial hazards along the food
885 supply chain, and the end use of food products. As a result, the report recommends a risk-based
886 approach to water use and reuse instead of defaulting to specifying the use of potable water or
887 other water quality types (FAO/WHO, 2019).
888
889 As described earlier, different applications of reused water require different water quality
890 standards. For food contact applications, there are specific US regulations and WHO guidelines
891 on the need to have equivalence to potable water to prevent adulteration of food products with
892 biological hazards (Anonymous, 1999; WHO, 2017). The equivalence to potable water should be
893 based on quality indicators, and therefore risk assessment methodologies should incorporate
894 these quality indicators when evaluating the safety of reused water.
895
896 Assessing public health risks of an intervention requires quantifying the risk in absolute (i.e.,
897 total public health impact) or comparative (i.e., increase/decrease in public health risks from
898 status-quo) terms. For example, assessing the risks from a regulated animal product new to the
899 market would require estimating the absolute public health impact of that product, whereas
33
900 knowing if a new regulatory intervention effectively reduces foodborne illnesses would require a
901 comparison of illnesses against current interventions.
902
903 Although potable water is safe, food products generated with potable water can still have certain
904 public health risks due to pathogen contamination throughout the production chain. Thus, reused
905 water for use in animal processing should be evaluated to ensure that its use does not result in a
906 net increase (i.e., relative to current water usage practices) in the number of human illnesses,
907 hospitalizations, and deaths attributable to animal products under USDA FSIS regulations.
908 Answering the question of reused water would be amenable to a comparative risk assessment
909 framework.
910
911 Regulatory risk assessments applied to food safety risk assessment were published, and should
912 follow Codex guidelines, chiefly Principles and Guidelines for the Conduct of Microbiological
913 Risk Assessment (CXG 30-1999) (FAO/WHO, 2001) and Working Principles for Risk Analysis
914 for Food Safety for Application by Governments (CXG 62-2007) (FAO, 2007). These guidelines
915 describe the main components of a risk assessment as hazard identification (identify food safety
916 hazard(s) from the intervention), exposure assessment (estimating the extent of anticipated
917 human exposure to the hazard as a result of the intervention), hazard characterization (estimating
918 the severity and duration of negative health outcomes resulting from exposure to the hazard), and
919 risk characterization (obtain a population-level estimate of the public health risks resulting from
920 the intervention). In the US, the USDA FSIS and the US EPA have published the Microbial Risk
921 Assessment guideline (US EPA, 2012b) for pathogenic organisms in food and water to achieve a
922 more consistent approach to microbial risk assessment across federal agencies. Such efforts have
923 resulted in an emphasis by US agencies regulating food on performing these fit-for-purpose risk
924 assessments, rather than following formulaic or overly strict risk assessment frameworks
925 (Dearfield et al., 2014). USDA FSIS also published a repository of current and past quantitative
926 risk assessments performed since the late 1990s in a variety of inspected products, mostly
927 concerning microbial contaminants (USDA FSIS, 2020a). Likewise, the US FDA makes
928 available to the public a variety of risk assessments and risk assessment resources for microbial
929 and chemical hazards (FDA, 2020).
930
34
931 Based on the principle of fit-for-purpose risk assessment, FSIS and the industry should assess the
932 public health risks using a risk assessment approach for water reuse in food contact applications
933 that do not already require potable water quality. The risk assessment models should be
934 adaptable to the specific food and processing situations. The diversity in the different water use
935 scenarios and food products makes it difficult to recommend any specific risk assessment
936 framework (e.g., qualitative versus quantitative microbial risk assessment), but it should be
937 useful to create a series of use cases to provide examples and guidance of possible risk
938 assessments to apply in FSIS inspected products.
939
940 As proposed by the FAO-WHO (2019), following a risk assessment, a decision tree could be
941 used to assist industry in deciding the fit-for-purpose of water reuse under four different
942 applications (i.e., as food ingredient, intentional food contact, unintentional food contact, not for
943 food contact) and conditioning scenarios. An example of a relevant decision tree is provided in
944 Figure 4-1. Thus, the risk assessment and decision trees framework should be flexible enough to
945 accommodate such diversity.
946
947 Effect of Residual Contaminants on Materials Added During Food Processing
948
949 Residual contaminants (refer to Glossary), as indicated by high turbidity in non-potable, recycled
950 water may inhibit the ability of antimicrobials added to the water to reduce pathogens in water or
951 food. Turbidity can interfere with disinfection and may include substances that allow microbial
952 growth (Chahal et al., 2016). Thus, highly turbid/contaminated water should not be used in the
953 facility before further processing (see responses to Charge Question #2).
35
955
956 What are the best ways to assure and/or monitor the quality and safety of alternatively
957 sourced water used in FSIS-regulated operations?
958
959 The safe use of reconditioned water requires monitoring to validate the initial processes and
960 ongoing verification so that water quality is consistent. The water source characterization and its
961 intended reuse will direct the allowable levels of substances. Initial monitoring of alternatively
962 sourced water should be extensive and may involve independent, accredited laboratories, while
963 ongoing performance monitoring should be in real-time and can focus on measuring indicators
964 rather than a complete analysis.
965
966 Source water (refer to Glossary) assessments consider a range of possible contaminants and can
967 be derived from lists such as the Guidelines for Drinking-Water Quality by (WHO, 2017) and the
968 WHO guidelines on the management of chemical contaminants (WHO, 2007). After the source
969 vulnerability assessment, it is not necessary to continually assess all potential contaminants and
970 analyses can focus on the relevant contaminants. The specific physical, chemical, and
971 microbiological parameters to be monitored, the frequency of monitoring, and on-line versus
972 discrete analyses should be chosen based on the distinct contamination vulnerability of the
973 source water.
974
975 Monitoring Quality and Safety of Alternatively Sourced Water
976
977 Effective methods to monitor and ensure water quality and safety are in use by municipal
978 wastewater treatment plants. Removal of nutrients and pathogens has been the focus of these
979 facilities for over 100 years. The same methods can be used for alternatively sourced water.
980 Typical wastewater treatment is monitored (using indicators) for the elimination of all
981 pathogenic microorganisms, except for spores.
982
983 Monitoring parameters for recycled water include investigative, process performance, and
984 verification. Initially, an investigative, comprehensive assessment of water contaminants in the
36
985 source water should be done, as they may impact recycling. Annual water analysis should
986 document the overall quality of the incoming water and meet the regulatory requirements.
987 Standard water analysis methods are available, well-developed, and reliable (APHA, 2005). The
988 potential contamination in waters is evaluated by testing different parameters, such as pH, total
989 dissolved solids, total organic carbon (TOC), ammonia nitrite, nitrate, hydrogen sulfide,
990 dissolved oxygen, chloride, chlorine, sodium, sulphate, turbidity, urea, etc. TOC is an excellent
991 indicator of the treatment process performance and there are manual and in-line monitors
992 systems for rapid and inexpensive TOC evaluation. Total dissolved solids can be detected by
993 electrical conductivity, a measurement that provides information on dissolved inorganic ions in
994 water.
995
996 The presence of potential human pathogens is evaluated by testing for bacterial indicators, such
997 as aerobic plate counts (counts of total bacteria), coliforms, Escherichia coli, etc. Depending on
998 the incoming source, an initial analysis for lipid, protein, lactose/sugar, and minerals may be
999 needed to be sure the water quality will not adversely affect product or process. After the water is
1000 used in processing, other tests should be considered, such as testing for residues of sanitizers or
1001 the accumulation of metal cation. The type of parameters to monitor, and the frequency, will also
1002 depend on whether the water is used directly on foods or food contact surfaces versus the use on
1003 non-food contact surfaces.
1004
1005 The physical parameters of water include turbidity, which is an important indicator of microbial
1006 quality (bacteria, parasites, viruses). In-line turbidity meters with alarm systems are available at
1007 relatively low cost. Depending on the intended water use, real-time monitoring of turbidity is
1008 recommended, and standard acceptable levels have been set (US EPA, 2018a).
1009
1010 The chemical parameters of water coming into the facility from outside should be known. There
1011 should be an initial testing when a new source of water is used. Once the composition of the
1012 source water is known and the treatment process is in place, the chemical composition does not
1013 need frequent monitoring. There are numerous chemical indicators used to characterize the
1014 quality of the water, such as specific metals (e.g., Fe, Mn, Pb), radionuclides (e.g., radium
1015 226/228 and uranium in particular), anions (e.g., SO4, NO3-), silica, nutrients (e.g., NH3-,
37
1016 phosphorus oxyanions), and some specific synthetic organics. Color is generally an indicator of
1017 organics in the water and is readily measured by visual or spectrophotometric methods. Odor is
1018 important and can be checked by smell for objectionable aromas of sulfide or algal products.
1019
1020 Disinfectant residuals such as chlorine, chlorine dioxide, or chloramine residuals could be
1021 detrimental for some products. Ozone dissipates rapidly and ultraviolet light provides immediate
1022 disinfection with no residual. One or more disinfectants are required as part of the treatment
1023 process to ensure microbial safety. Additionally, routine residual measurements are important to
1024 establish presence and/or absence of residuals. Inexpensive disinfectant residual test kits are
1025 available. However, in-line monitors for chlorine and ozone are preferred for continual
1026 monitoring of microbial safety.
1027
1028 The microbial parameters of water should be monitored frequently because contamination risks
1029 are acute. Reclaimed water (refer to Glossary) used in direct or indirect contact with product
1030 should receive secondary treatment with disinfection. Also, for non-contact water reuse
1031 identification of potential fecal contamination is an issue for worker safety.
1032
1033 Safety indicators can include monitoring filtration, disinfection, and the presence of residual
1034 disinfectants. In general, and for different types of waters (e.g., drinking, recreational, animal
1035 processing, etc.), microbiological water testing detects indicator organisms, instead of specific
1036 pathogens, as a sign of fecal contamination. However, it is important to emphasize that many
1037 microbial indicators (e.g., coliforms, E. coli, enterococci) have been used to assess fecal
1038 pollution, but there is no direct correlation between the numbers of any microbial indicator in
1039 water and the presence of an enteric pathogen (Grabow, 1996, Ashbolt, et al., 2001).
1040
1041 Heterotrophic plate count (refer to Glossary) estimates the number of live heterotrophic
1042 microorganisms in water and provides some information about water quality. Yet, the test itself
1043 does not specify the organisms that are detected and results in a wide range of quantitative and
1044 qualitative results (WHO, 2001). Total coliforms are another bacterial group that can indicate
1045 potential contamination, but coliforms can originate from many sources and are not good
1046 sanitary waste indicators. Another group are the FIB (see response to answers for Charge
38
1047 Question #3), which have been used by public health agencies for several decades to identify
1048 potential for illness resulting from recreational activities in surface waters contaminated by fecal
1049 pollution (US EPA, 2012c).
1050
1051 The US EPA recommends the use of FIB, specifically enterococci and E. coli, as indicators of
1052 fecal contamination for fresh water, and enterococci as indicators of fecal contamination for
1053 marine water (US EPA, 2012c; 2012d). FIBs are considered “pathogen indicators” (refer to
1054 Glossary), but the Agency recognizes that these microbial groups are not used as direct
1055 indicators of pathogens by the scientific community (US EPA, 2012c). In addition, the Agency
1056 has not yet published any criteria for pathogens per se (US EPA, 2012c).
1057
1058 Historically, Escherichia coli was considered an appropriate indicator organism for determining
1059 the potential presence of bacterial fecal pathogens in reused wastewater. However, contemporary
1060 research highlights that Escherichia coli may not be an effective indicator of water quality
1061 because it appears and grows in natural environments in addition to the intestines of warm-
1062 blooded animals (Whitman and Nevers, 2003). The large diversity within Escherichia coli
1063 strains, and the actual sources of the majority of the Escherichia coli strains isolated from the
1064 environment may not be identified by a library-dependent method (refer to Glossary) (Ishii et al.
1065 2007; Jang et al., 2017). The use of other indicators, such as bacteriophages (McMinn et al.,
1066 2017), to assess fecal pollution and enteric virus removal in recreational water also brings
1067 uncertainties and have limitations for the modeling of microbial populations in recreational
1068 water. Thus, we do not know the most appropriate indicators for each food animal species that is
1069 processed. However, as our knowledge in this area increases, we expect to find other
1070 microorganisms, or DNA markers, that could be used to assess the level of pollution in waters.
1071
1072 Microbiome sequencing has been suggested as the next method to help evaluate the efficacy of
1073 cleaning and sanitation practices, antimicrobial intervention, and to provide information on the
1074 quality of recycled water in animal processing establishments (Blevins et al., 2017; Feye et al.,
1075 2020). Microbiome mapping using DNA data from next generation sequencing may help
1076 processors understand the key microbes on the food product and in the processing water.
1077
39
1078 There are real-time, in-line monitors systems to evaluate physicochemical properties quality of
1079 recycled water. In-line monitors are available for pH, conductivity, turbidity, particle counts,
1080 TOC, and many individual chemicals. In-line electrical conductivity monitors are inexpensive
1081 and provide information on salinity, while in-line pH systems are simple and cost-effective.
1082 Other in-line monitoring systems are expensive and require regular calibration, maintenance,
1083 and trained personnel. There are no real-time, in-line monitoring systems to detect and count
1084 microorganisms yet. However, signals from in-line chlorine and turbidity tests could in the future
1085 be used to assess the level of microbial contamination in water.
1086
1087 Verification monitoring is needed when a system does not meet specifications and corrective
1088 action is implemented. This monitoring assures performance and requires an increased frequency
1089 until specifications for the specific parameter are consistently met. This is critical if the recycled
1090 water has any product contact potential.
40
1092
1093 Are there special considerations for foods that are produced entirely within water (e.g.,
1094 fish), and if so, what are they?
1095
1096 The answers to this specific question focus on the growing, transporting, and processing of
1097 channel catfish (Siluriforme fish).
1098
1099 Pond Water
1100
1101 Channel catfish (Siluriforme) are raised primarily in ponds in the southern states of Mississippi,
1102 Alabama, Arkansas, and Texas, accounting for 95% of annual US sales of channel catfish.
1103 Channel catfish production was valued at $380 million in 2018 in the US (NASS, 2019) and over
1104 90% of the commercial channel catfish is produced in embankment/levee type of ponds, which
1105 keeps the water free of pollutants and other species of fish. These water impoundments are
1106 constructed on flat land where the dirt has been moved into a levee around the pond bottom and
1107 usually range from 8 to 25 acres with a depth of 4 to 6 feet (Anonymous, 2020). Another system
1108 of channel catfish production is the split-cell pond, where a traditional pond is split in half with
1109 an earthen dam. This system is more efficient and may increase the production per acre
1110 compared to embankment/levee type of ponds, but it requires much more intensive aeration
1111 management due to the increased stocking rate (Coblentz, 2017).
1112
1113 The ponds in which channel catfish are produced must yield fish that are healthy and wholesome
1114 for human food consumption. Ponds are typically filled with non-treated water from a ground
1115 well. This water is used throughout the fish growing period and is replenished as needed. Water
1116 conservation measures have been implemented to maximize capture of rainwater and at the same
1117 time prevent ponds from overflowing and losing water during heavy rains (Tucker et al., 2016;
1118 Tucker et al., 2017). Some ponds are drained and refilled annually; however, most ponds are
1119 often used for up to 10 years without draining.
1120
41
1121 Maintaining good water condition is essential to control fish diseases and to provide adequate
1122 production of channel catfish. As with all food animal production systems open to the
1123 environment, fishponds could potentially become exposed to foodborne pathogens from other
1124 animals (wild and domestic) that have access to the area, but it does not appear to impact the
1125 success in raising wholesome channel catfish (USDA FSIS, 2017). Because the water is used all
1126 year and replenished as needed, there is no economic, or other types of incentives, for water
1127 conservation/recycling, although some conservation practices have already been described
1128 (Tucker et al., 2017).
1129
1130 Producers monitor pond water for production-related parameters (e.g., dissolved oxygen,
1131 temperature, pH, alkalinity, hardness, total ammonia nitrogen, etc.), while USDA FSIS is
1132 responsible for monitoring ponds for environmental chemicals and pesticides that can impact
1133 food safety (USDA FSIS, 2017).
1134
1135 Transport Water
1136
1137 Catfish are harvested from ponds and transported to the processing establishments in live-haul
1138 trucks that contain aerated water-filled tanks. The water in transport tanks may be sourced from
1139 well water or the production pond. Wynne and Worts (2011) recommended that the transport
1140 truck be scrubbed using a detergent, followed by a disinfection spray and then rinsed. It is
1141 unclear if this recommendation is regularly followed in the industry. If trucks are used for
1142 multiple runs from the same pond, disinfecting after every load may not be practical. Cleaning
1143 and disinfecting trucks is a biosecurity measure to control the spread of diseases between fish
1144 rather than a sanitation measure associated with food processing. Reduction of water use in
1145 catfish transportation appears to be unlikely due to the concern with preventing transport stress
1146 and disease transmission between loads.
1147
1148 Processing Water
1149
1150 Channel catfish processing comes under the jurisdiction of the USDA FSIS; therefore, Sanitation
1151 Performances Standards and Standard Operating Procedures apply to water use and water supply
42
1152 as mandated by 9 CFR 416.2(g) (Anonymous, 1999; USDA FSIS 1999). These requirements are
1153 adequate for channel catfish processing. As with other food animal processing, there may exist
1154 possible water reclamation and reuse opportunities if the wholesomeness of the product is not
1155 compromised.
1156
1157 Guimarães et al. (2018) evaluated the possible reuse of water in seafood processing in Brazil.
1158 These authors evaluated industrial water management and quantified and qualified eﬄuents from
1159 general processing activities and concluded that direct reuse of processing water would not be
1160 recommended due to the high number of bacterial contaminants. However, the authors also
1161 concluded that indirect recycling of water from freezing tunnel and cooling chamber defrosting
1162 could be used to supply cooling tower demands after a simple treatment and disinfection process.
1163 It was estimated that this practice might reduce total average water consumption of the
1164 processing unit by 11%. It was also noted that if eﬄuents from cooling tower purges were also
1165 reused, water reduction levels of approximately 22% could be attained.
1166
1167 Similar to the high number of bacterial contaminants described by Guimarães et al. (2018), other
1168 food industries (e.g., beef processing and poultry processing) that have implemented processes to
1169 capture, treat and reuse water, have also reported high levels of bacterial contaminants in the
1170 water captured for recycling (Casani et al., 2005). However, various treatments have been proven
1171 to be effective at bringing the water back to potable standards in order to be reused (Casani et al.,
1172 2005). Although technologies for the recycling of water in food manufacturing exist, which
1173 could also be useful in recycling water in the fish industry, these technologies would have to be
1174 economically beneficial for the processing facility to implement.
1175
43
1177
1178 Flooding can contaminate animals and water sources with human sewage and farm waste.
1179 What precautions should establishments take when floodwater or runoff affects a food or
1180 water source, or a processing area?
1181
1182 Flooding events are considered “significant incidents” by USDA FSIS, meaning they represent
1183 grave or potentially grave threats to people or products. These events could trigger a “Significant
1184 Incident Response” by the Agency (USDA FSIS 2018). Depending on the scope of the
1185 emergency, such an event could trigger response actions under the National Response
1186 Framework, National Response Plan, and State emergency management activities (USDA FSIS
1187 2019). The USDA FSIS “Significant Incident Preparedness and Response” program is a resource
1188 for education, collaboration and assistance with preparing emergency response plans (USDA
1189 FSIS 2020b).
1190
1191 Food production companies should have documentation for managing natural disasters, such as
1192 flooding in a facility, that clearly define preparedness and response actions. This documentation
1193 may be a corporate-level document that outlines general action items for establishments, and/or
1194 establishment-level contingency plans or emergency response plans. These documents will give
1195 direction on how to manage such situations, and typically include checklists that provide
1196 guidance. General guidance on flooding preparedness is available for processing facilities,
1197 including small and very small facilities, at the USDA FSIS website (USDA FSIS, 2013).
1198 Companies also need to consider following state guidelines (e.g., Emergency Action Planning
1199 Guidance for Food Production Facilities by the New Jersey Department of Health) (Anonymous,
1200 2012).
1201
1202 A documented flood emergency response plan can give a facility’s staff a step-by-step course of
1203 action to follow in times of need and help minimize losses for a business. Time invested in
1204 training and educating staff members for natural disasters will help to keep team members and
1205 animals safe.
1206
44
1207 Industry-driven audits of food safety systems require facilities to have procedures designed to
1208 effectively manage and report incidents and potential emergency situations that impact food
1209 safety, quality or legality, including appropriate contingency plans. Incidents such as fire, flood,
1210 natural disaster, malicious contamination or sabotage, digital cyber-security, etc., may include
1211 disruption to key services such as water, energy, transport, refrigeration processes, staff
1212 availability and communication. Facility operators should consider whether products from the
1213 site may be affected by an incident before releasing them to market.
1214
1215 Floods or other natural disasters affecting an animal production facility need an immediate and
1216 humane response to find, assess and secure the affected animals, consistent with the provisions
1217 of the Animal Welfare Act (USDA APHIS, 2020), and with worker safety. If animals are present
1218 in a facility during a flooding event, facility managers should follow established and applicable
1219 Animal Welfare Policies to remove animals to a safe and secure area (USDA FSIS, 2011, 2015),
1220 which include moving animals to safe locations, rinsing them down if heavily soiled, managing
1221 and containing animal waste and contaminated water in accordance with applicable regulations,
1222 rinsing down and cleaning all surfaces, sanitizing animal contact surfaces with approved
1223 products, and forced air drying to prevent mold growth.
1224
1225 Following a flooding event in which flood water has entered an animal or processing facility,
1226 managers should follow the SOPs in their emergency response plan to mitigate facility
1227 contamination and damage in order to return the facility to a safe operational state. Large
1228 debris/gross contamination can be removed from surfaces by removing them with clean water.
1229 Fans or other mechanical drying equipment can be used to dry wetted surfaces more quickly to
1230 reduce potential molding. Surfaces that have been contaminated by floodwater should be cleaned
1231 with an approved cleaning product appropriate to the setting and operational process. If these
1232 surfaces come in contact with animals or animal products, they should be sanitized with an EPA-
1233 registered sanitizer.
1234
1235 A facility’s emergency response plan should also take into consideration potential damage to,
1236 and contamination of, the facility’s water supply and distribution system. Whether for worker or
1237 animal health, maintaining facility operations, or product quality, a safe water supply is a critical
45
1238 resource that needs to be incorporated into emergency preparedness and mitigation plans for
1239 animal growing and processing (Appendix #1). Water-related emergency preparedness at a
1240 facility includes understanding the water supply and how water is used in the facility. Flood
1241 water can contain pathogens, chemicals and toxins that can contaminate a facility’s water supply
1242 at its source, during treatment, or during distribution. If mitigation or preventive measures are
1243 not taken, this contaminated water may be consumed by workers or used for facility production
1244 processes like animal care and facility cleaning. Clean, safe water is essential for human and
1245 animal consumption, proper hygiene, surface cleaning, and handwashing. It is important for
1246 facilities to ensure their water supply is safe for intended purposes (Appendix #1).
1247
1248 If a facility is served by a municipal water system that experiences flooding, managers should
1249 check with the local water authority to determine if a drinking water advisory has been issued,
1250 and any precautions that should be considered (CDC, 2020). Many water utilities also offer text-
1251 based alert systems for rapidly notifying customers of any drinking water advisories. State health
1252 departments may also have guidance on emergency planning for water advisories and
1253 interruption of water service (Anonymous, 2012). If the facility uses a groundwater well,
1254 managers may consider consulting a well or pump contractor to have the well inspected to
1255 determine if it or associated equipment has been damaged during flooding or is not working
1256 properly. If managers suspect that a facility’s groundwater source might have been contaminated
1257 by floodwater, they can contact their local or state health department or agriculture extension
1258 office for advice on disinfecting the well (CDC, 2016). Before resuming use for drinking or
1259 production, the well should be tested for appropriate fecal and chemical water quality parameters
1260 (CDC, 2009).
1261
1262 A facility’s water emergency and preparedness plan will include detailed information and
1263 procedures to enable facility staff and remediation personnel to respond to and recover from
1264 interruption of the facility’s water supply. This plan will typically identify alternate water
1265 sources and mitigation procedures (e.g., posting signage that water is not safe for consumption,
1266 employing alternate procedures if tap water is not appropriate for process use). In addition to
1267 considering alternate water supplies, facility managers can benefit from planning for actions to
1268 remediate the facility’s water supply, distribution, and building plumbing systems (also known as
46
1269 “premise plumbing”). Mitigation planning includes identifying water system repair and
1270 rehabilitation companies that can quickly respond following a flood event, having documents
1271 ready to assist in the system repair and rehabilitation process, and ensuring that the facility water
1272 system is effectively flushed to remove contaminated water and contaminant residues (Bartrand
1273 et al., 2018).
1274
1275 The guidance documents from CDC and American Water Works Association (AWWA) on
1276 developing emergency water supply plans for healthcare facilities may be helpful to animal
1277 growth and production facilities. The CDC and AWWA’s Emergency Water Supply Planning
1278 Guide for Healthcare Facilities has checklists and decision trees that could be adapted to food
1279 production facilities during the preparation for, and response to, a water supply interruption
1280 (CDC AWWA, 2012). Similar guidance could be developed to provide information and tools to
1281 food processing facilities interested in developing water preparedness plans.
1282
1283 Steps and considerations in preparing a food processing facility water preparedness plan include
1284 (Figure 7-1):
1285
1286 1: Identify the facility’s water supply and operations team.
1287 2: Understand facility water usage by conducting a water use audit, including assessment of
1288 facility water taps and processes that could present risks that may need to be mitigated if the
1289 water supply is suspected to have been compromised by flooding.
1290 3: Analyze the facility’s emergency water supply alternatives.
1291 o Review and incorporate applicable rules and guidance from local, state and federal
1292 authorities.
1293 o Identify alternate sources of water that can be obtained and used for facility
1294 operations, including drinking or use in facility processes.
1295 o Identify critical partners that can assist with obtaining alternate water sources or
1296 rehabilitate the facility’s established water source and building plumbing system.
1297 4: Develop and test the Emergency Water Supply Plan.
1298 o Develop messaging examples to provide facility workers with guidance on
1299 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
1305
1306 What technologies are appropriate for the replacement of liquid water in food production
1307 and food processing areas (i.e., foam, mist, or dry chemicals)? What advanced emerging
1308 technologies may reduce the need or volume for water in processing?
1309
1310 Alternate water-sparing processes may be considered, such as air chilling a product in place of
1311 chilling in a water bath and using recycled water and wastewater for specific purposes (refer to
1312 Charge Question #2). Recycled water can be used for product-contact equipment rinsing,
1313 provided that the provisions of 9 CFR 416.2(g)(3) and (4), where applicable, are properly
1314 addressed (Anonymous, 1999; USDA FSIS, 1999). Strategies that prevent contamination from
1315 being brought into a clean processing area may enhance the overall effectiveness of a cleaning
1316 program, such as using boot disinfection stations and limiting wheeled equipment to specific
1317 zones. Staff training with regular updates can maintain and reinforce cleaning and water-sparing
1318 behaviors.
1319
1320 Cleaning, sanitizing and disinfection are critical components of a facility’s operations program
1321 during routine operations and for recovery activities following a flood or other contamination
1322 event. Cleaning is the process of removing contaminants from a surface that could be harmful to
1323 human or animal health, damage equipment, lead to process inefficiency, or impact product
1324 integrity or safety. Cleaning processes and chemical products are not designed to kill bacteria,
1325 viruses or fungi, but rather to remove them from surfaces along with dirt, oils, and other
1326 inorganic and organic materials. Sanitizing and disinfecting (refer to Glossary) are related
1327 concepts, as both are focused on killing or inactivating microorganisms, including pathogens.
1328 Disinfectant products and processes are those that result in a more rigorous removal or
1329 inactivation of microorganisms of public health concern than sanitizing products (sanitizers) and
1330 sanitizing processes (Appendix #2). For example, there are no sanitizer-only products with EPA-
1331 approved virus claims, but there are sanitizer-only products with EPA-approved bacteria claims,
1332 as vegetative bacteria (though not bacterial spores) are generally easier to inactivate than viruses
1333 (Sobsey, 1989).
1334
49
1335 When choosing a sanitizer or disinfectant, it is important to consider what level of sanitizing or
1336 disinfection is indicated for each facility process, and what the product is registered to do (i.e.,
1337 the label claims). Some products can have both claims, as a sanitizer and as a disinfectant,
1338 depending on variables such as concentration and contact times (Appendix #2).
1339
1340 The general steps in cleaning and sanitizing food contact surfaces are site-specific and variable.
1341 Wet cleaning of an establishment includes a cleaning step, which may include the use of
1342 detergents, to remove, as much as possible, organic matter and may be accompanied by physical
1343 actions, such as scrubbing, pressure, etc. The sanitizer(s) is(are) applied after cleaning. Dry
1344 cleaning protocols (refer to Glossary) also include mechanical removal of soil or residue, aided
1345 with vacuum, compressed air, or compressed steam, and wiping with alcohol-based swabs or
1346 moistened pads, followed by towel drying (Table 8-1). Dry sanitizing and disinfection treatments
1347 can reduce microbial contamination, using products based on a variety of mechanisms of
1348 antimicrobial action and approved by the EPA for use on food contact surfaces (Table 8-2). A
1349 critical final step is often a disinfectant treatment that may intentionally leave an antimicrobial
1350 residue.
1351
1352 Most cleaning, sanitizing and disinfection approaches standard in the protein food processing
1353 industry are water intensive. Several water-sparing technologies may have uses that could reduce
1354 dependence on water for these basic steps (Tables 8-1 and 8-2). Many of these technologies were
1355 developed first for use in dry and ready-to-eat food processing environments, where waterless
1356 cleaning and disinfection has been widely adopted, and may also have applications in meat and
1357 poultry processing. Novel sanitizers and disinfectant strategies may offer similar bacterial load
1358 reduction and disinfection while using less water. Whole room or closed chamber treatments
1359 with fogs or ultraviolet light may help reduce bacterial loads on exposed surfaces without
1360 requiring any water at all. Surface treatment preparations that do not require a final rinse may
1361 reduce water use.
1362
1363 Sanitizers and disinfectants for use on food contact surfaces are registered as antimicrobial
1364 pesticide products with the EPA under FIFRA (refer to Charge Question #3), which reviews data
1365 from standard microbial reduction effectiveness assays to validate public health claims for
50
1366 particular uses, such as treatment of hard surfaces (US EPA 2012c, US EPA 2018b). Whole
1367 room treatments using disinfectant products delivered as a fog are registered for that delivery
1368 system. But novel cleaning and sanitizing products may help reduce use of water. For instance,
1369 cleaning solutions based on quaternary ammonium compounds can be used with pre-moistened
1370 wipes as an alternative to well-established chlorine-based wipes. Sanitizing solutions based on
1371 ~60% isopropyl alcohol and quaternary ammonium compounds may introduce little water.
1372
1373 Ultraviolet light treatments and ozone applications may have applications in enclosed spaces, as
1374 an adjunct to other treatments, with adequate precautions for worker safety. These alternatives
1375 (ultraviolet light and ozone applications) are regulated by the EPA as devices, and are not
1376 registered, nor granted health claims by the Agency (US EPA 2020). EPA is also developing
1377 regulatory strategies for the new and rapidly expanding category of surface treatments or
1378 coatings with sustained antimicrobial properties. Copper alloys, which are registered by the EPA
1379 as surface antibacterials with limited sanitization claims and not for food contact surfaces (US
1380 EPA 2016), have been described for use in hospitals and other clinical facilities, and have limited
1381 though long-lasting effects, and validated bacterial effect claims (Muller et al., 2016). Some
1382 coatings are registered but do not have public health pathogen claims. Silver alloys have been
1383 incorporated into poured floors and other surfaces to make them more mold and mildew
1384 resistant. Surface treatments for food contact surfaces may offer a longer lasting residual
1385 antimicrobial effect, though published practical experience with them is limited. Similar
1386 experience is beginning to be reported from healthcare settings (Boyce, 2016). Once a standard
1387 test protocol is developed, including assessment of how long effectiveness lasts, more coatings
1388 with residual antimicrobial effects lasting for weeks or months are likely to be registered with
1389 specific health claims. In the future, with more published experience and EPA registration, such
1390 technologies may offer efficient sanitizing and disinfection in combination with more routine
1391 cleaning methods, while using less water.
1392
1393 When considering a novel technology, it is important to evaluate several critical points:
1394
1395 1. Is the new technology involving sanitizing or disinfecting registered with the EPA as either a
1396 sanitizer or as a disinfectant for use on food contact surfaces? The appropriate criteria for one
51
1397 or the other (Appendix #2), need to be met if the technology is to be used for those purposes
1398 on a food contact surface. If the new technology is a device or surface coating, the company
1399 will need to evaluate the available antimicrobial effect data, as these are not registered with
1400 the EPA for health claims.
1401 2. What published or other experience is available showing that in a practical use case the
1402 technology achieved reductions in both the pathogen load and in the volume of water used in
1403 cleaning and disinfection? The nature of that experience needs to be carefully considered,
1404 including whether the impact was measurable with standard monitoring tests already in use
1405 in the facility’s water use plan. A hierarchy of evidence has been described for evaluating
1406 products used in the health care sector (McDonald and Arduino, 2013). A similar approach
1407 may be useful in evaluating reported experiences in the food processing sector.
1408 3. Does the technology make economic sense, so the value of the water saved at least equals the
1409 cost of applying the novel strategy? That may include the cost of water piped in, and
1410 sewerage costs incurred, as well as the cost of implementing the new technology
1411 (Timmermans, 2014).
1412 4. Is the new process readily accepted by the workforce? What additional training and ongoing
1413 reinforcement will be needed?
1414 5. How can existing sanitization performance standards and sanitary standard operating
1415 procedures be adapted to include the new process? Are ongoing environmental and product
1416 monitoring tests in place to provide ongoing assessment of the impact on microbial targets?
1417 6. If it is adopted, what evaluation at future time points will be made, to see what the impact is
1418 on the actual water use as measured in the ongoing water management plan?
1419
52
1420 Tables
1421
1422 Table 1-1. Estimated amount of water used during processing by species
1423
Species Water Usage Adjusted per Kg Comments
Average
Broiler 18.9 to 37.8 (average 26.5) L per 2.3 8.5 to 11.5 L per Avula et al., 2009/
chickens kg broiler (Avula et al., 2009; kg of broiler meat Calculated usage by
Northcutt and Jones, 2004; Micciche processing step
et al., 2018)
Micciche et al., 2018
Beef 4,947 liters by ton LCW 1 (Li et al., 4.2 L per kg of Li et al. 2018. Includes
2018) meat water for processing and
4,200 to 16,600 liters by ton LCW cleaning and sanitizing
(Jones 1993) 3 to 5 (small
2,299 liters per carcass (Beckett and establishments) up Jones, 1993. Estimated
Oltjen, 1993) to 10 to 11 (large water use in beef
3,000 to 5,000 (small establishments) processing ranging from
establishments) up to 10,000 to liters per kg 4,200 to 16,600 L/t
11,000 (large establishments) liters LCW
per ton (Warnecke et al. 2008)
Turkey 41.6 to 87 liters per turkey N/A CAST, 1995
1424
1
1425 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 LD4 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
1
1434 There is limited information on the water use in amenities and plan service (e.g., cooling,
1435 heating) services.
2
1436 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.
3
1439 The wash cabinets are areas for potential water reuse and water conservation.
4
1440 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 Water Completing a good dry pick up of excess packaging
Program Minimization material, product waste and excessive soils prior to
implementing the pre-rinse can save time, energy and
water.
Optimize cleaning Plant CIP/COP1 Water Chose right cleaner for soil type, water quality, surface
minimization to be treated, method of application and based on
environmental guidelines.
Chilled and hot Utilities Factory Water Water leaks are always an issue and eliminating leaks
water leaks Minimization, will conserve water.
Leaks
Condensate return Utilities Factory Condensate Condensate systems and steam traps will result in some
and traps water savings, but mostly will result in energy savings.
Poor steam trap Utilities Factory Steam Systems, Leaking steam traps will waste energy and water as
operation Leaks both steam and condensate.
Re-use sample Utilities Factory Water Reuse Anywhere where a stream of water is used
water 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 Hand wash stations left running wastes water
Shutdown
Hose stations Sanitation Factory Equipment Hoses are used for floor cleaning and equipment wash
Shutdown, Water down. Often, they are left running, have had nozzles
Minimization 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 Program water.
place (COP1)
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
1
1446 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 Summarized committee Risk assessment
Risk analysis step(s)
Question question(s) question(s)
#4a, b, d How do residual contaminants in Can reconditioned water Hazard identification
water used for animal reduce product quality
production, slaughter, and and safety? Can this
processing affect product quality change result in
and safety? What are the quality increased public health
implications and public health risks?
risks associated with
contaminants at levels
anticipated for reconditioned
water?
#4c How might FSIS and industry Quantify the additional Comparative risk
best assess those implications public health risk from assessment (i.e.,
and risks? using reconditioned exposure assessment,
water (vs status-quo hazard characterization,
potable water usage) risk characterization)
#5 What are the best ways to assure How do we monitor and Risk management, risk
and/or monitor the quality and control public health communication
safety of alternatively sourced risks from using
water used in FSIS-regulated reconditioned water?
operations?
1451
1452
58
1453 Table 8-1. Cleaning mechanisms with potential for decreasing facility water use.
1454
Cleaning Type Mechanism/Delivery
Mechanical Manual tools (brushes, cloths, scrapers, scrubbing)

Detergent wipes, Dry ice/CO2
Vacuum
Compressed air/High-pressure “Dry ice/CO2
Ultrasonic bath (for COP)
Chemical Enzymatic foam
Spray
Atomizing
Thermal “Dry” Steam
1455
1456
59
1457 Table 8-2. Sanitization or disinfection products and devices with potential for decreasing facility
1458 water use.
1459
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
Antimicrobial materials or May reduce microbial burden on

coatings surfaces and floors (less frequent and
lower use of water for cleaning and
disinfection)
Thermal Steam or dry heat 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
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
urpose: Purpose:
• Notforfood contact applications I Re-used water I • Food contact applications (food or
• No microbiological requirements ~ I food contact surfaces)
for consumer food safety • Microbiological Safety requirement:
re-use water should not compromise
consumer safety
Ir
Is contact of t he reuse
water (as rec laimed/ • Fit-for-purpose
recycled) with food Are microbiological hazards for intentional
materials impossible due absent in the reuse water and unintentional
to passive management, or present at acceptable food contact
i.e. design and levels, i.e. levels that do not applications
infrastructure of Food compromise the consumer • Build active
operation? food safety of the concerned management into
ingredient/food? your food safety
N y management
N
system, including
validation of
' control measures
Is active management feasible as well as
to consistently exclude contact Can reuse water be treated Y monitoring and
of reuse water with food to avoid presence of hazards ~ verification of
materials? or to control hazards to control during
acceptable levels? day-to-day
N y operation
' ' N
• Notfit-for • Fit-for-purpose
purpose for all not-for-food
'
• Do not use this Can application of reuse • Fit-for-purpose
contact
reuse water water be limited to only for food
-
applications
source or • Assure water is applications other than y applications other
supply without separately stored as food ingredient or than as ingredient
reconditioning those not contaminating or final cleaning/
and transported
food materials or contact washing
from water for
surfaces? • Build active
food contact
management into
applications
N your food safety
• Verify active
management
management
system, including
when additionally • Not fit-for-purpose.
needed validation,
• Consider only
monitoring and
"not-for-food contact"
verification
applications that
effectively exclude contact
of reuse water with food
materials or contact
1468
surfaces
1469
61
1470 Figure 7-1. Developing an Emergency Water Supply Plan (EWSP)
1471
STEP 1 STEP 2 STEP 3 STEP 4
IDENTIFY the UNDERSTAND ANALYZE the DEVELOP and

facility’s water water usage facility’s water exercise the
supply & locations & supply EWSP
operations team processes alternatives
1472
1473
62
1474 Appendices
1475
1476 Appendix #1. Critical water usage in animal growth and processing facilities
1477
1478 • Consumption and essential health & safety functions
1479 • Handwashing
1480 • Drinking
1481 • Food production and preparation
1482 • Animal care
1483 • Fire suppression
1484
1485 • Equipment and sanitary purposes
1486 • Flushing toilets
1487 • Cleaning and sanitizing/disinfecting facility and equipment
1488 • Heating, ventilation, and air conditioning
1489
63
1490 Appendix #2. Sanitizers and disinfectants. Examples of measures of effectiveness required for
1491 EPA registration for use on hard food contact surfaces.
1492
1493 • Sanitizers for use on hard surfaces (Food contact surfaces) (US EPA 2012c):
1494 • After treatment, 105 reduction in numbers of Salmonella enterica and
1495 Staphylococcus aureus
1496 • No efficacy claims for viruses or other non-bacterial pathogens
1497
1498 • Broad spectrum disinfectant on hard non-porous environmental surfaces (US EPA
1499 2018b):
1500 • 60 test surfaces (carriers) with 105-106 Salmonella enterica/carrier
1501 • 60 test surfaces (carriers) with 106-107 Staphylococcus aureus/carrier
1502 • After treatment, no more than 1 carrier positive for Salmonella, and 3 positives
1503 for Staphylococcus
1504 • Disinfectant claims for viruses can also be based on efficacy testing
1505
64
1506 Glossary
1507
1508 Activated sludge. A wastewater treatment process where sewage or industrial wastewaters are
1509 treated by aeration and a biological floc, or sludge blanket, composed of bacteria and protozoa to
1510 remove organic pollutants.
1511
1512 Alternatively sourced. Water not from a municipal water treatment plant.
1513
1514 Antimicrobial agent. Substance used to preserve food by preventing growth of microorganisms
1515 and subsequent spoilage, including fungistats, mold and rope inhibitors, and the effects listed by
1516 the National Academy of Sciences/National Research Council under "preservatives" (21 CFR
1517 170.3(o)(2)).
1518
1519 Biological oxygen demand. The amount of oxygen consumed by bacteria and other
1520 microorganisms while they decompose organic matter under aerobic conditions at a specified
1521 temperature.
1522
1523 Chemical oxygen demand (COD). The amount of oxygen consumed to chemically oxidize
1524 organic contaminants in water to inorganic end products. It is a measure of water and wastewater
1525 quality, and it is used to monitor water treatment plant efficiency. This test is based on the
1526 principle that strong oxidizing agents in acidic environments will oxidize almost any organic
1527 compound to carbon dioxide.
1528
1529 Clean. To remove soil, dirt, grease – any objectionable, visible material.
1530
1531 Cleaning-In-Place. A process that uses water rinses, hot caustic and/or acid recirculation,
1532 precise temperatures, and turbulence to clean soils and bacteria microbial contaminants from the
1533 inside surfaces of food production equipment, Equipment such as, mixing tanks, pumps, valves,
1534 storage vessels.
1535
1536 Cleaning-Out-of-Place. A process of cleaning equipment items at a designated cleaning station.
1537 Equipment could include fittings, clamps, product handling utensils, tank vents, pump rotors,
1538 impellers, casings, hoses, etc.
1539
1540 Clean water. Water which does not compromise the safety of the food in the context of its use.
1541
1542 Cleaning product/compound/substance. A substance or mixture of substances (such as
1543 chemical or biological substances) that is intended to clean away or remove inanimate material
1544 from a surface, water or air.
1545
1546 Contaminant. Any undesirable chemical substance, microorganism or physical matter present in
1547 a sample.
1548
1549 Disinfection. A process performed to eliminate many or all pathogenic microorganisms, except
1550 bacterial spores, in a liquid (e.g., water) or on inanimate objects.
1551
65
1552 Dissolved air flotation. A water treatment process that clarifies wastewaters (or other waters) by
1553 the removal of suspended matter such as oil or solids. The removal is achieved by dissolving air
1554 in the water or wastewater under pressure and then releasing the air at atmospheric pressure in a
1555 flotation tank basin. The released air forms tiny bubbles which adhere to the suspended matter
1556 causing the suspended matter to float to the surface of the water where it may then be removed
1557 by a skimming device.
1558
1559 Dry cleaning. The removal of food residue with mechanical action.
1560
1561 Fecal coliform. A type of bacterial count as determined by approved methods of analysis (40
1562 CFR 136.3).
1563
1564 GRAS (generally recognized as safe). A substance that is generally recognized, among
1565 qualified experts, as having been adequately shown to be safe under the conditions of its
1566 intended use, or unless the use of the substance is otherwise excepted from the definition of a
1567 food additive. The general recognition of safety is based on 1) scientific procedures, through the
1568 views of experts qualified by scientific training and experience to evaluate the safety of
1569 substances directly or indirectly added to food, or 2) history of the use of the substance prior to
1570 January 1, 1958 (21 CFR 170.3). In 2016, FDA issued a final rule that amended and clarified the
1571 criteria for when the use of a substance in food for humans or animals is not subject to the
1572 premarket approval requirements of the Federal Food, Drug, and Cosmetic Act because the
1573 substance is considered GRAS under the conditions of its intended use (FDA 2016).
1574
1575 Heterotrophic plate count. A variety of simple culture-based tests that are intended to recover a
1576 wide range of heterotrophic microorganisms, which are microorganisms that require organic
1577 carbon for growth and include bacteria, yeasts and molds. This test was formerly known as
1578 “standard plate count,” and the test methodology involves a wide range of test conditions, such
1579 as incubation temperatures varying from 20°C to 40°C, or incubation times varying from a few
1580 hours to a few weeks, and nutrient conditions of the medium varying from low to high (WHO,
1581 2001).
1582
1583 Indicators. Microorganisms whose presence in water indicates the potential presence of a public
1584 health hazard.
1585
1586 Library-dependent method. A range of bacterial source tracking techniques based on the
1587 isolation, phenotyping, and genotyping of indicator bacteria from different sources, such as fecal
1588 sources and water samples (Mott and Smith, 2011).
1589
1590 Moving bed biofilm reactor. A water processing system that optimizes the use of a sludge
1591 activated sand biofilter to utilize the whole tank volume for biomass growth (Ødegaard et al.,
1592 1994).
1593
1594 No contact. Water in the meat processing environment that does not touch product or product
1595 contact surfaces (e.g., environmental sanitation of non-meat product contact surfaces inside the
1596 processing environment, as a diluent for cleaning and sanitizing chemicals used in CIP systems
1597 or manual sanitation, excluding the final CIP water rinse).
66
1598
1599 Pathogens. Disease-causing organisms (generally certain viruses, bacteria, protozoa, or fungi).
1600
1601 Pathogen indicators. A substance that indicates the potential for human infectious disease
1602 (Clean Water Act, section 502(253)). Enterococci and generic E. coli are indicators. They do not
1603 cause human illness because they are not human pathogens, but they indicate the presence of
1604 fecal contamination.
1605
1606 Potable water. Drinking water that meets or exceeds state and federal drinking water standards.
1607
1608 Quantitative microbial risk assessment. The application of probabilistic models to estimate the
1609 order of magnitude of risk of infection and illness when a population is exposed to specific
1610 microbiological hazards.
1611
1612 Reclaimed water. Water that was originally a constituent of a food, has been removed from the
1613 food by a process step, and has been subsequently reconditioned when necessary, such that it
1614 may be reused in a subsequent food manufacturing operation. Water that has been treated to be
1615 fit-for-purpose for reusing or recycling.
1616
1617 Reconditioning. The treatment of water intended for reuse by means designed to reduce or
1618 eliminate microbiological, chemical, and physical contaminants, according to its intended use.
1619
1620 Reconditioned water. Water that has never contained human waste and is returned to safe
1621 drinking water standards via treatment by an onsite advanced wastewater treatment
1622 facility. Reconditioned water can be used on raw product and throughout the facility provided
1623 that product or equipment that contacts reconditioned water receives a final rinse with non-
1624 reconditioned water that also meets safe drinking water standards. Reconditioned water cannot
1625 be used on ready-to-eat products (citation: 9 CFR 416.2(g)(4)):
1626
1627 Recycled water. Water, other than first use or reclaimed water, that has been obtained from a
1628 food manufacturing operation and has been reconditioned when necessary, such that it may be
1629 reused in a subsequent food manufacturing operation.
1630
1631 Residual contaminants. Impurities remaining in water after the implementation of a remedial
1632 action.
1633
1634 Reuse. The recovery of water from a processing step, including from the food component itself;
1635 its reconditioning treatment, if applicable; and its subsequent use in a food manufacturing
1636 operation.
1637
1638 Reused water. Recycled and reclaimed water.
1639
1640 Sanitizers. Antimicrobial pesticides used to reduce, but not necessarily eliminate,
1641 microorganisms from the inanimate environment to levels considered safe as determined by
1642 public health codes or regulations. Sanitize. To reduce microorganisms of public health
1643 importance (and other undesirable microorganisms) to levels considered safe. Sanitized surface.
67
1644 Adequately treat cleaned surfaces by a process that is effective in destroying vegetative cells of
1645 pathogens, and in substantially reducing numbers of other undesirable microorganisms, but
1646 without adversely affecting the product or its safety for the consumer.
1647
1648 Sequencing batch reactors. A type of activated sludge process for the treatment of wastewater.
1649
1650 Source Water. A place from which water is obtained; a municipal water supplier, a well, a
1651 spring, a fountain, etc. More generally: a place from which water can be obtained.
1652
1653 Turbidity. The measure of relative clarity of a liquid. It is an optical characteristic of water and
1654 is a measurement of the amount of light that is scattered by material in the water when a light is
1655 shined through the water sample. The higher the intensity of scattered light, the higher the
1656 turbidity. Material that causes water to be turbid include clay, silt, very tiny inorganic and
1657 organic matter, algae, dissolved colored organic compounds, and plankton and other microscopic
1658 organisms.
1659
1660 Wastewater. Used water.
1661
1662 Water conservation. More efficient use of water, resulting in reduced demand for water.
1663 Sometimes called “end-use efficiency” or “demand management.”
1664
1665 Wet cleaning. The process of removing food residue with water and chemicals.
1666
1667 Water reuse. Water, ice, and solutions used to wash or chill product, which is maintained free of
1668 contamination and recirculated on the processing line. Water can only be reused for the same
1669 purpose (e.g., water used at evisceration can only be reused within the evisceration
1670 process). Reused water can be treated but does not need to meet safe drinking water standards.
1671 (citation: 9 CFR 416.2(g)(2-3).
1672
1673 Water reconditioning. The treatment of water intended for reuse by means designed to reduce
1674 or eliminate microbiological, chemical, and physical contaminants, according to its intended use.
68
1675 References
1676
1677 Aguilar, M. I., Saez, J., Llorens, M., Soler, A., Ortuno, J. F. 2002. Nutrient removal and sludge
1678 production in the coagulation flocculation process. Water Res. 36 (11), 2910e2919. Available at
1679 http://dx.doi.org/10.1016/S0043-1354(01)00508-5.
1680
1681 Almandoz, M. C., Pagliero, C.L., Ochoa, N. A., Marchese, J. 2015. Composite ceramic
1682 membranes from natural aluminosilicates for microfiltration applications. Ceram. Int. 41 (4),
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1684
1685 Al-Mutairi, N. Z., Al-Sharifi, F. A., Al-Shammari, S.B. 2008. Evaluation study of a
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1688
1689 Amorim, A. K. B., De Nardi, I. R., Del Nery, V. 2007. Water conservation and effluent
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1693 Anonymous, 1977. Secondary direct food additives permitted in food for human consumption.
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1697
1698 Anonymous. 1999. Title 9 Code of Federal Regulations Part 416.2(g). Sanitation, Subchapter
1699 E—Regulatory requirements under the Federal Meat Inspection Act and the Poultry Products
1700 Inspection Act. Federal Register 64 FR 56417, Oct. 20, 1999. Available at
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1702 2.pdf.
1703
1704 Anonymous. 2008. Efficient use of water in export meat establishments. Australian Government
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1708
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1712
1713 Anonymous. 2020. Pond construction for catfish farming. Extension publication. Mississippi
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1725 Avery, L. M., Killham, K., Jones, D. L. 2005. Survival of E. coli O157:H7 in organic wastes
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The Use of Water in Animal Production, Slaughter, and Processing

ADOPTED 22 APRIL 2021, WASHINGTON, DC

407 • Electrocoagulation: Electrocoagulation is a cost-effective technology that has been

412 • Membrane Technology: Membrane technology, which includes technologies such as

Turkey 41.6 to 87 liters per turkey N/A CAST, 1995

Evisceration 7.57 Refer to Carcass washes

Mechanical Manual tools (brushes, cloths, scrapers, scrubbing)

Antimicrobial materials or May reduce microbial burden on

STEP 1 STEP 2 STEP 3 STEP 4

IDENTIFY the UNDERSTAND ANALYZE the DEVELOP and

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