Environmental Health has a programme of risk assessments and reviews under the Private Water Supply Regulations 2016 "the Regulations" for all private water supplies serving commercial businesses or more than one domestic property.
Regulation (EC) No. 852/2004
Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs lays down specific rules regarding water supplies utilised by food businesses. Chapter 7, 1(a) in particular states that: 'There is to be an adequate supply of potable water, which is to be used whenever necessary to ensure that foodstuffs are not contaminated'. 'Potable water' means, in this instance, water meeting the minimum requirements laid down in Council Directive 98/83/EC (as amended by Regulation (EC) No. 1882/2003) on the quality of water intended for human consumption.
Failure to assure a consistent safe supply of water could potentially pose a risk to health not only via consumption, but indirectly via contaminated foodstuffs.
Food Safety Management System
Any documented food safety management system should include the necessary control measures, monitoring procedures, contingency plans etc. for a private water supply.
Any documented HACCP (hazard analysis critical control point) based system should include an assessment of the necessary control measures, monitoring procedures (e.g. daily checks that the treatment is fully functional), contingency plans etc. to ensure a consistent, safe supply of water is provided as part of the food operation.
Water Safety Plan (WSP)
A water safety plan considers the risks to a private water supply, the treatment facilities, the distribution infrastructure including pipes, reservoirs or tanks, and the internal pipe work within premises, and measures to prevent or control contamination from 'catchment to tap'. One of the key elements of a water safety plan is the identification of the hazards and the risks associated with those hazards. This element is described as a 'risk assessment' and is undertaken by the District Council on a five yearly cycle.
We recommend that a WSP includes:
- The risk assessment report/letter
- Site plan
- Details of water treatment and maintenance schedule
- Checks and Maintenance records
- Sampling results
- List of contact details for servicing/repair
- Emergency procedure in the event of a sampling failure or loss of supply
It is not mandatory to have a WSP, but it is strongly recommended that a food business with a private water supply has one. If a food business does not have a WSP which includes an emergency procedure in the event of a sampling failure, there should be a similar document in the Food Safety Management System.
A food business on a supply shared with dwelling houses or another business will not always be sampled as part of the sampling programme implemented following a risk assessment, as sampling can be undertaken at different outlets on the supply. A food business may, therefore, wish to undertake additional sampling.
Treatment at a food business
Standard recommendation for microbiological treatment is:
- A pre-filter (UV will not work well if there is particulate matter in the water)
- UV treatment
- Failsafe system (An audible or visual alarm and a shut off valve that prevents water entering the system if the UV treatment is not functioning.)
A food business should seek professional advice from a Water Consultant regarding the most appropriate chemical and biological treatment for their business.