Of course, consumers in most markets are protected to the point where the manufacturer of substandard products could face criminal or civil proceedings as well as product withdrawal or import refusal. Moreover, public health enforcement agencies are joined by industry organisations to ensure product safety, and monitor whether producers are following ‘best practice’ manufacturing processes.
Bottled water is well-regulated. In the US, for example, bottled water is fully regulated as a packaged food product by the US Food and Drug Administration and bound by the FDA’s quality, safety, inspection and labelling requirements.
The packaged water industry relies on the safety of bottled water as one of its major selling points. Indeed, packaged water companies use a ‘multi-barrier approach’ to bottled water safety, which includes source protection, source monitoring, reverse osmosis, distillation, filtration and other purification techniques such as ozonation or ultraviolet (UV) light.
Aside from adhering to the various industry regulations, the best way to minimise the risk of contaminated water is to have a good Hazard Analysis and Critical Control Point (HACCP) plan in place, yet this isn’t as straightforward as it may sound.
On the surface, the seven principles of a HACCP system (see list below) may seem easy to implement, but it’s not without reason that consultants can charge a small fortune to help companies implement such plans. Regardless of the cost, it’s worth the investment because it helps to satisfy business owners and their customers that products are safe in an efficient, reliable and cost-effective way. It achieves this by focusing on hazard prevention throughout the product life cycle rather than relying on end-product testing.
The seven principles of HACCP
The definition of a hazard (according to the European Federation of Associations of Health Product Manufacturers) is anything that can harm the consumer, and can include biological, chemical and physical hazards. Preventive measures are the actions that are required to remove or reduce the hazard occurrence to an acceptable level.
The HACCP team should include key personnel from all parts of the business, such as microbiologist, production manager, quality assurance manager, engineer and purchasing manager. Team members need to have relevant practical experience, knowledge of the products and processes within the factory and suitable training in how to undertake a HACCP study, including how to implement HACCP principles.
At least one member of the team should have formal HACCP training, but all team members need to be trained in how to utilise the HACCP principles. Members of the team are also responsible for the ongoing review and management of the plan.
In situations where a company has called on expert advice in the form of an external consultant (to help with either the development or the maintenance of the HACCP plan), it’s important that the management team shouldn’t delegate responsibility to the external resource. The consultant should be considered purely in an advisory role, as responsibility for ensuring that the bottled product is safe should always come down to the company itself.
Once you’ve assembled your team and perhaps hired a qualified consultant to help everyone through the process, the initial step will be to construct a production flow diagram.
The verified flow diagram will help the team in locating all points throughout the production process that could be potential problem areas. These Critical Control Points (CCPs) need to be listed along with preventive measures to control hazards. It’s necessary to establish target levels and tolerances for each CCP in order that the preventive measures be effective. The thresholds will be set for observable or measurable parameters (eg moisture levels, pH, texture, etc) and should be based on firm evidence that the chosen values will lead to process control.
Once values have been established, a monitoring system (and the corrective actions to be taken when monitoring identifies a deviation from target values) should be decided on and recorded. The monitoring system (the when, how and who will measure target levels) must be documented, along with actions taken to correct any problems that have occurred.
This treasure trove of data can become invaluable for long-term analysis and can help plant management by cutting costs and revealing issues that are difficult to spot in the short-term.
Magdalena Kogutowska writes for Water Innovation magazine.
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