New hurdles for water reuse

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Courtesy of Zentox Corporation

In a letter dated January 19, 2005, the USDA-Food Safety Inspection Service (FSIS) indicated that if water is to be reused in a poultry processing facility, then this reuse water must be accounted for in the plant’s HACCP program. This requirement may cause some difficulties as processors consider the associated hazard analyses.

When water is used to chill or rinse broiler carcasses, fat, protein, blood, fecal material and ingesta may be deposited into the water. Additionally, pathogenic bacteria commonly found on broiler carcasses, may end up in the water as well. To prevent processors from using spray or chiller rinse wa- ters directly upstream as reuse water, and thereby possibly contaminating chickens upstream, USDA has enacted new regulations described in CFR 416.2 (g) (3). This regulation requires that, for reuse water to be used upstream, measures be taken to reduce physical, chemical and microbiological contamination to a level appropriate for use in their pro- cess to prevent contamination or adulteration of product. Some poultry plants interpret this to mean that as long as they are somewhat reducing the number of bacteria in the rinse or chill waters prior to reuse, it is acceptable to use upstream. Although the USDA is aware of this practice, no new regulations have been enacted to disallow it.

What impact may the new ruling have on processors? The USDA-FSIS is mainly concerned about three areas: 1) the scalder, 2) water taken from the inside/outside bird washer (IOBW) and other rinsers and used upstream, and 3) chiller red water rechilling systems. The USDA-FSIS has indicated that scalder water should be considered “recycled” water because water is used on a carcass after passing over a previous carcass. Thus, it is considered reused and must be incorporated into the HACCP plan. Any water that is collected from an IOBW or other rinse system and used upstream is considered reuse water. Chiller water is also considered reused when it is removed from the chiller at the suction box, rechilled, and then added back to the chiller through the redwater return pipes. It can be argued that the scalder and chiller are a single process and that you cannot, by definition, reuse water in a single process because the scalder and chiller are common baths. Thus, theoretically, bacteria that the carcasses entering the system may be ex- posed to are capable of contacting carcasses at other areas within the tanks during scalding or chilling.

Because these systems are considered reuse, the USDA- FSIS will require that processors verify that these systems are reducing bacteria. The following are specific recom- mendations for verifying the efficacy of each of these sys- tems. They have been prepared in detail and are considered acceptable to the USDA as a means of verification.

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