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Kathy Griffiths Challenges Enfor

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Kathy Griffiths Challenges Enfor Powered By Docstoc
					Challenges and the practical issues
  with enforcing the Regulations




Kathy Griffiths, Chartered Environmental Health Practitioner
Law specifically relevant to bottled
             water...

     The Natural Mineral Water, Spring
      Water and Bottled Drinking Water
      Regulations 2007
     They are relevant to all water other
      than tap water
     Natural mineral water:

   Is microbiologically wholesome
   Emerges from a spring or tapped via
    a borehole from aquifer
   Nature is preserved intact
   Is characterised by its mineral
    content
   Must be bottled at source
Water Sources

        They are a water
         company’s lifeblood
        Water sources must be
         protected against
         deliberate and unintended
         contamination
        They must be protected
         from surface water
               Parasites

   Examples include Giardia and
    Cryptosporidium
   Come from cattle, sheep & wildlife
   These have been a serious problem in
    some tap waters but are not found in
    UK bottled waters
   The BWCA requires a 1 micron filter on
    bottling lines
   Care is needed when changing filters
Source Protection
Inside the well protection
        building…

                Everything washable
                Protected from pests
                Security from other
                 intruders
                Frequent monitoring of
                 the water
                Water protected from
                 the air
    Reg 16 - Checking and Enforcement

   Relevant authority must:
   Look periodically on recognised NMW to
    check composition, temp and that “essential
    characteristics” remain stable
Sampling Water from source -how
            often?
   FSA recommend at least once a year
   Also recommend that bottler tests water daily
    for micros, chemical and physical parameters
   Bottlers don’t always send LA’s the results
   Take great care with samples and sampling
    technique
       For the period of 12 hours
            following bottling
   The total colony count of water at source shall not
    exceed-
    (i) 100 per ml at 20 to 22°C in 72 hours; and
    (ii) 20 per ml at 37°C in 24 hours; and
    (b) water shall be maintained at a temperature of
    4°C +/- 1°C.

   How does that relate to bottled water in shops?
Water from Coolers
Potential Problems with Bottled Water
              Coolers…
      They need sanitising regularly – the
       BWCA states every 13 weeks
      Once a bottle is positioned on the
       cooler the water should be drunk
       ideally within 3 weeks
      Algae can grow if the cooler or water
       is in sunlight
      Consumers often misuse coolers –
       thinking drip trays are connected to a
       drain etc.
      Consumers may try to re-fill the
       bottles themselves
                           Ozone
   It’s a gaseous disinfectant
   It kills bacteria and can oxidise pesticide residues
   It breaks down quickly to oxygen
   It can be a good back up for bottle washing and can be
    used to sanitise coolers and pipework
          …but…
   You still have to pre-clean the cooler before ozonating it
   It can be harmful if health and safety precautions are not
    followed
   Over ozonation of water can cause high bromate levels
   It’s not allowed for spring or natural mineral water
    Containers and Closures…

   Closures must be designed to avoid
    the possibility of adulteration or
    contamination
   Containers and closures must be
    made from food safe materials
   Bottlers must have info on file and
    keep traceability details
   Media scrutiny about
       Antimony with PET bottles,
       bisphenol A (BPA) from PC bottles
There are of course always the worriers and
water seems to fascinate them
Another interesting development by
           restaurants…
     Take ordinary tap water, pass it
      though a series of filters
     Add some (optional) carbon
      dioxide
     Bottle it
     Charge as much as if you were
      selling “normal” bottled water
     It has now become bottled
      drinking water
    There must be a catch…

   A maintenance contract with the installer is
    needed to keep the filters working and
    replaced regularly.
   The bottles need cleaning properly. They
    must be washed vertically in dish washers -
    if they are just laid on the tray they will not
    be cleaned.
   The taps used for filling the bottles and the
    rest of the equipment need looking after
    and kept clean. Just because the treatment
    unit looks clean and shiny doesn’t mean
    you can forget about it.
         Personal hygiene
   The person filling the bottle must be as
    well-trained and hygienic as they are when
    they are producing food.
   Proper, enthusiastic hand washing
    remains the number one priority.
   Restaurants with one of these need to
    make sure they understand what it does
    and when it needs servicing.
   Be safe, not sorry, water is a great carrier
    of germs from unwashed hands to
    unsuspecting tummies.
            For the future…

   David Clapham is trying to set up a
    group of interested EHP’s who have
    water bottling plants in their area and
    would like to discuss common issues
    with others
   If you haven’t made contact with him
    yet…
    David.clapham@bradford.gov.uk
          And finally…

As Benjamin Franklin said:

In wine there is wisdom,

In beer there is freedom,

In water there is bacteria.