Beyond Integrity Testing: Validating NF/RO for Pathogen Removal Under the Membrane Filtration Guidance Manual Regulatory Framework

Although significant progress has been made toward the development of continuous direct integrity test methods for NF/RO systems, the current industry discourse has largely overlooked the challenge testing requirements described in the Membrane Filtration Guidance Manual (MFGM). However, some state regulators may be unwilling to grant significant pathogen removal credit to NF/RO unless these challenge testing requirements can be satisfied. This presentation discusses the adaptation of the challenge testing requirements of the LT2ESWTR membrane regulatory framework to NF/RO, addressing critical questions and a potential path forward for reconciling the technology to the regulations for compliance.