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Proposed Draft Guidelines for the Hygienic Reuse of Processing Water in Food Plants (Agenda Item 8)[10]

103. The Delegation of the United States introduced document CX/FH 00/8 and noted that the Proposed Draft Guidelines (Annex A to CX/FH 00/08) were recommended to be a new Annex to the International Recommended Code of Practice: General Principles of Food Hygiene. The Delegation indicated that the commodity specific examples of water reuse, presented in Annex B, were for informational purposes only and should be removed from this text, although specific examples could usefully be incorporated while developing individual codes of hygienic practice, such as those for fresh cut fruits and vegetables or those for dairy foods.

104. The Committee agreed to consider further only the Proposed Draft Guidelines, section by section.

105. The Delegation of the United Kingdom, supported by the Representative of the EC and suggested that a new section, “Objective,” be added to the Guidelines document in which the primacy of potable water would be emphasized, and that deviations from this standard practice be fully justified. The Delegation of Austria indicated that reused water should be at least free of pathogens. Some delegations noted that reused water coming in contact with food should always be potable. However, other delegations noted that, in fact, non-potable water was routinely and extensively used in food processing and that Section 5.5.1 (Water in Contact with Food) of the Recommended International Code of Practice: General Principles of Food Hygiene allowed exceptions. It was noted that this section indicated that “water recirculated for reuse should be treated and maintained in such a way that no risk to the safety and suitability of food results from its use”. There was a general agreement to add a new section “Objective” to emphasize the importance of potable water and recognize the exceptions in case of reused water, and that precise wording of the content of Objectives be further discussed by drafting partners.

106. Concerning the Scope of Annex A, it was noted that the second sentence of the Introduction section should also include reference to recirculated water in addition to recycled and reclaimed water. The Committee agreed to move the second and third sentences of the Introduction to the Scope. It was noted that also the last line of Introduction should be included in the Scope. The Committee agreed to reconsider the Scope.

107. Regarding Definitions, the Committee agreed to remove prescriptive statements concerning the need for reconditioning from the definitions for recirculated, recycled and reclaimed water and that such statements should appear later in the text.

108. The Committee had significant initial discussions on the Guidelines. Several Delegations noted the need for greater flexibility with respect to HACCP (Section 4.3 of Guideline). The Committee agreed that the wording in Section 5.1 of the Recommended International Code of Practice: General Principles of Food Hygiene provided less rigid wording and agreed to its use for Section 4.3 of the Guidelines. The use of the term “quality” in Section 4.4 of the Guidelines was questioned and the Committee agreed that the term should be replaced by “suitability”. It was further agreed to move Section 4.10 of the Guidelines toward the top of the “Guidelines” listing in order to give it added prominence.

109. The Committee noted that the current document lacked clarity regarding the difference between reuse water that comes into contact with food and reuse water that does not. The Committee concluded that this difficulty needs to be resolved and that the focus of the document should be on water that comes into contact with food.

110. The Committee agreed to return the Proposed Draft Code to Step 3 for redrafting by the United States with the assistance of their drafting partners in light of the comments received and the discussions of the current session, and to circulate it for comments prior to the next session of the Committee.

[10] CX/FH 00/8; CX/FH 00/8-Add.1 (comments of Denmark, Mexico, the United States of America and IDF); CRD 17 (comments of Italy, CRD 20 (comments of Philippines).

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