This session will confront the generally accepted position that if water is good enough to drink, it is good enough to use for food processing. Speakers will analyze the data on whether/how the gap between EPA Drinking Water and FDA FSMA policies leave a hole in the middle that can compromise food safety and dialogue about solution models. The Revised Total Coliform Rule (RTCR; effective 4/2016) refocuses the Safe Drinking Water Act criteria on fecal Escherichia coli as the indicator for fecal contamination, and total coliforms as the indicators of pathways through which contamination can enter the system. Public systems will be required to do an assessment if their sampling results indicate that they are vulnerable to contamination. It changes requirements for public notification when samples are positive in favor of triggered assessments (“find and fix”). Users may not be informed that microbially contaminated water was provided, especially if the system implemented a fix or even a plan for a fix within the required time frame. While impact on individuals drinking might be minimal, food processors who rely on municipal water could be contaminating their products. Municipal water can be used for processing (food contact or even ingredient water) without any risk assessment because FSMA specifically excluded municipal water users from requirements to address water in their written Food Safety Plans. In reality, some systems served exclusively from ground water supplies are not disinfected. Recent research in Minnesota (where 567 groundwater systems were compliant and did not disinfect) found EPA compliant water, when not disinfected, can be contaminated with Salmonella and other organisms of concern. Viable pathogens can intrude, through non-point sources or through the pipe and pump hydraulics, and go undetected by monitoring under the Revised Total Coliform Rule. Our current statistics do not capture the link between food outbreaks where the underlying transmission agent or amplification is in the “drinking water”. Here, government panelists discuss: How big is the hole in the middle and can it compromise food safety? What should we do about it?

Presentations