BAINBRIDGE ISLE, Wash. — “Water bottlers are taking an unnecessary risk relying on antiquated equipment to produce ozone for water disinfection,” said Valbona Malo, global business manager for NSF International’s Beverage Quality Program.
NSF International was founded in 1944 as the National Sanitation Foundation to standardize sanitation and commercial food equipment requirements and today provides testing and certification for food equipment, dietary supplements and bottled water.
This is important as food safety and product quality has come under greater scrutiny since the adoption of the Food Safety Modernization Act (FSMA) in 2011.
“This was a positive move toward preventative action rather than corrective,” explained Malo, who is based in Brussels and also serves as chairman of the WE (Watercoolers Europe) Education & Audit Committee Education and represents NSF for the European Federation of Bottled Water. “Bottlers are required to document what they do and do what they document.”
Under the law, the Food and Drug Administration (FDA) has the ability to charge food processors for the re-inspection of facilities that are found to be deficient during the routine first inspection.
“Taking a staged or phased approach is key,” said Malo. “I would suggest starting by implementing a Hazard Analysis and Critical Control Points (HACCP) plan and recommend that the HACCP team leader take a certified HACCP training course as well as a course on the principals of internal auditing.” NSF International offers several courses and a readiness tool (http://info.nsf.org/extranet/fsma/) to help prepare for, and comply with, FSMA regulations.
Ozone has been used for bottled water disinfection for decades but older systems may have difficulty maintaining desired set points. This problem has been attributed to manually controlled ozone generators and lack of proper monitoring technology. As a water bottler, the single CCP in the HACCP program is dissolved ozone residual. Without an in-line monitor driving the generator through a PID control, ozone levels are erratic. And without ambient monitoring a bottling plant is at risk if there is an ozone leak, which could lead to EPA and OSHA air quality concerns.
In addition to an ozone generating unit, industry experts say a system should include in-line monitors and closed-loop control for optimum safety and efficacy, and ambient monitors ensure precise ozone concentrations.
“There are many reasons bottlers should upgrade old equipment,” concluded Malo. “But the most important one is meeting your customer’s expectations for product quality and safety, by maintaining a sound HACCP program.”
Water bottlers must identify potential gaps in their food management safety systems and provide practical steps to develop and implement an effective control program. Upgrading the ozone disinfection program is a critical part of that process.
