The water used in frozen food production — washing raw ingredients, blanching vegetables, making sauces and marinades, forming ice glazes on seafood, and cooling finished products — is a critical quality control point that increasingly intersects with PFAS contamination concerns. As food safety agencies and advocacy groups extend their focus from drinking water to food production water, frozen food manufacturers face growing pressure to understand and manage PFAS in their manufacturing water systems.
Water’s Role in Frozen Food Manufacturing
Water is integral to frozen food production processes in ways that vary by product type:
Vegetable processing: Blanching (brief heat treatment that inactivates enzymes and sets color) uses large volumes of hot water; subsequent cooling uses additional water. PFAS in the process water contact the vegetable surfaces and can partially be absorbed.
Seafood processing: Fish and shellfish are glazed with ice immediately after harvest/processing to prevent dehydration and freezer burn. Glazing uses water that freezes onto the product surface — any PFAS in the glazing water becomes part of the product’s ice coating and may be ingested when the product is consumed and the glaze melts.
Ready meals and prepared foods: Sauces, soups, and prepared components are formulated with water as a primary ingredient. PFAS in manufacturing water become part of the product formulation at their source concentration (before any concentration effects during cooking).
Packaging cooling: Continuous water sprays or immersion cooling are used to rapidly lower product temperature after cooking. Contact between the packaging and cooling water may allow PFAS transfer through packaging materials.
PFAS Sources in Food Manufacturing Water
Food manufacturing facilities can face PFAS in their process water from:
- Municipal water supply contamination (most common source for facilities on public water systems)
- On-site wells drawing from contaminated groundwater
- Recycled process water that concentrates PFAS with each cycle
- Fire suppression system discharge or AFFF use near food production areas
Regulatory Status of PFAS in Food Processing Water
The FDA regulates water used in food processing as part of its oversight of food manufacturing under the Food Safety Modernization Act (FSMA). FSMA’s water quality provisions focus primarily on microbial contaminants for fresh produce, but PFAS are beginning to appear in FDA’s broader food safety investigations.
Several states have extended their PFAS water testing requirements to food manufacturing facilities, particularly in states where agricultural and food production PFAS contamination has been documented. The FDA’s ongoing PFAS in food market basket studies will provide data that may drive more specific federal requirements.
Industry Response and Best Practices
Forward-looking food manufacturers in PFAS-affected regions have begun implementing proactive measures:
- Annual PFAS testing of all process water sources using EPA Methods 533 and 537.1
- Installing reverse osmosis or activated carbon treatment at process water intake points where PFAS are detected
- Verifying treatment system performance through product water testing
- Transitioning to PFAS-free food contact materials (packaging, cooking equipment, processing surfaces)
- Supplier verification programs for food ingredients that may have been irrigated with PFAS-contaminated water
Consumer Implications
For consumers, PFAS in frozen food production represents an exposure pathway that is essentially invisible and difficult to control through individual action. Choosing frozen products from manufacturers with transparent water quality programs and PFAS-free packaging — and advocating for stronger FDA standards for PFAS in food processing water — represents the most effective approach. For households particularly concerned about food-based PFAS exposure, cooking frozen vegetables with PFAS-filtered water rather than adding any tap water during preparation is a minor but meaningful step.