Paul Industries designs, installs and qualifies water for injection and purified water systems across South Carolina. A plant here is unusually likely to answer to two pharmacopoeias at once, because South Carolina’s manufacturing base is heavily European-owned. That matters for water more than for almost any other utility, because until 2017 the European and American rulebooks disagreed about how water for injection may lawfully be made.

Request a quote or call 201-450-8280

The divergence Ph. Eur. required distillation for WFI; USP did not
The change Ph. Eur. monograph 0169, revised effective 1 April 2017
What it permits Purification equivalent to distillation, typically RO with EDI, UF or nanofiltration
Why it matters here German firms alone employ nearly 27,000 in South Carolina (SC Dept of Commerce)
Industrial power 6.84 cents/kWh, 0.84x the US average of 8.13 (EIA, 2024)
Reviewed September 2026, against current state code and EIA 2024 energy data

Two pharmacopoeias, one water system

South Carolina attracts European manufacturers at a rate few states match. The state’s Department of Commerce reports over 160 German companies alone, employing nearly 27,000 South Carolinians, with German capital investment exceeding $4.1 billion since 2011. France and other European countries add to that. The practical consequence for a regulated plant is that the site answers to its American regulator and to its parent’s European one, and the two are aligned but not identical.

Water for injection is where that difference was sharpest and is still most consequential for capital equipment. Until 1 April 2017, the European Pharmacopoeia permitted only distillation for WFI. The United States Pharmacopeia had long accepted any process equivalent or superior to distillation, in practice reverse osmosis coupled with an appropriate secondary membrane stage. A company with plants on both sides of the Atlantic therefore had two different water systems doing the same job, because one of them was legally obliged to boil.

The revision to Ph. Eur. monograph 0169, effective 1 April 2017, closed that gap. It permits WFI generation by a purification process equivalent to distillation, most commonly reverse osmosis, single or double pass, combined with electrodeionization, ultrafiltration or nanofiltration. That brought the European position materially closer to the American one.

What it did not do is make the two routes engineering equivalents, and that is the part worth being clear about before anyone specifies a system on cost.

Membrane WFI and distilled WFI are not the same system

A still is a thermal process. It is energy hungry and it is also self-sanitizing in a way membranes are not, because nothing microbiological survives the process. A membrane train is far more efficient and produces excellent water, but its microbiological control is designed in rather than inherent, and it depends on operating discipline that a still does not require.

That shifts the design burden downstream. A membrane-generated WFI system typically demands more attention to the distribution loop: continuous circulation at velocity, no dead legs, a defined sanitization regime whether hot water, ozone or steam, and monitoring that would be considered belt-and-braces on a distilled system. Where a still forgives a mediocre loop, a membrane train does not.

There is also a decision about temperature. Hot-loop WFI held above 65 degrees Celsius is microbiologically self-protecting and costs energy continuously. Ambient or cold loops save that energy and transfer the risk to sanitization frequency and to design quality. Membrane generation makes cold distribution more attractive economically, which is precisely why the loop design has to be better.

The two generation routes compared
ConsiderationDistillationMembrane route
Ph. Eur. statusAlways permittedPermitted since 1 April 2017 (monograph 0169)
USP statusPermittedLong permitted where equivalent to distillation
Microbial controlInherent in the processDesigned in; depends on operation
EnergyHigh and continuousSubstantially lower
Loop demandsMore forgivingVelocity, sanitization and monitoring discipline
Feed water sensitivityLowerHigher; pretreatment matters more
Continuous system electricity at South Carolina’s 6.84 cents/kWh
Continuous loadPer yearOver ten years
15 kW$8,988$89,880
30 kW$17,976$179,760
60 kW$35,952$359,520

At 6.84 cents per kilowatt-hour South Carolina sits below the national average, which narrows the running-cost argument for abandoning a still. The argument that survives is capital, footprint and capacity flexibility rather than pure energy.

What we build and how we qualify it

We design and install both routes and we have no stake in which one a site chooses. What we do insist on is that the choice is made against the actual regulatory audience. A site whose product never reaches Europe has more freedom than one whose batches are certified for the European market, and a site that expects to be acquired or to expand into Europe should specify as though it already is.

Qualification runs the same way regardless: design qualification against the user requirement specification, installation qualification covering materials, slopes, welds and instrumentation, operational qualification proving the system performs across its range, and performance qualification with the extended sampling program that establishes microbiological and chemical control over time. The sampling phase is where schedules slip, and it is the phase least amenable to compression.

Materials and construction follow ASME BPE, with orbital welding to AWS D18.1, weld documentation retained, and passivation to ASTM A967 after cleaning to ASTM A380. Conductivity and total organic carbon are monitored per USP 643 and USP 645 where applicable, and the endotoxin limit for WFI remains 0.25 EU/mL.

Standards referenced: ASME BPE · ASTM A967 · ASTM A380 · EIA electricity price data

Frequently asked questions

Do you build WFI and purified water systems in South Carolina?

Yes, across Greenville, Charleston, Columbia, Spartanburg and statewide: generation by either route, storage and distribution loops, sanitization systems, instrumentation and the full qualification package. We work with sites answering to FDA alone and with sites answering to a European parent as well.

Can water for injection be made without a still?

Yes, in both jurisdictions now. USP has long accepted a process equivalent or superior to distillation. The European Pharmacopoeia permitted only distillation until monograph 0169 was revised effective 1 April 2017, which now allows purification equivalent to distillation, most commonly reverse osmosis combined with electrodeionization, ultrafiltration or nanofiltration.

Is the membrane route simply better?

It is far more energy efficient and produces excellent water, but it is not an equivalent system. Distillation is inherently self-sanitizing because nothing microbiological survives it. A membrane train’s microbial control is designed in rather than intrinsic, so the distribution loop, the sanitization regime and the monitoring have to be better.

What does that mean for the loop design?

Continuous circulation at velocity, no dead legs, a defined sanitization regime whether hot water, ozone or steam, and monitoring that would look like belt-and-braces on a distilled system. Where a still forgives a mediocre loop, a membrane train does not, which is the trade being made when the still is removed from the budget.

Hot loop or cold loop?

Hot distribution above 65 degrees Celsius is microbiologically self-protecting and costs energy continuously. Cold or ambient loops save that energy and transfer the risk to sanitization frequency and design quality. Membrane generation makes cold distribution more economically attractive, which is exactly why the loop design then has to be better.

Why does this come up so often in South Carolina?

Because so much of the state’s manufacturing base is European-owned. The South Carolina Department of Commerce reports over 160 German companies employing nearly 27,000 people in the state, with more than $4.1 billion of German capital investment since 2011, and France and other European countries add to that. Those sites frequently answer to two regulators.

Should we design to the stricter reading even if we only sell domestically?

If there is any prospect of European market access, acquisition by a European parent, or contract manufacturing for one, yes. Retrofitting a water system to satisfy a second regulator is far more expensive than specifying for it at the outset, and the qualification effort largely has to be repeated.

What does qualification involve?

Design qualification against the user requirement specification, installation qualification covering materials, slopes, welds and instrumentation, operational qualification across the performance range, and performance qualification with an extended sampling program establishing control over time. The sampling phase is where schedules slip and is the least compressible part.

What standards do you build to?

ASME BPE for materials and construction, orbital welding to AWS D18.1 with weld documentation retained, passivation to ASTM A967 after cleaning to ASTM A380, and monitoring of conductivity and total organic carbon per USP 643 and USP 645 where applicable. The WFI endotoxin limit is 0.25 EU/mL.

How do I get a quote for a South Carolina water system?

Use the form on this page or call 201-450-8280. Useful inputs are peak and average demand, which pharmacopoeias you must satisfy and whether product reaches Europe, feed water quality, whether the loop will run hot or cold, and what qualification documentation your quality organization expects.

What changed in the European Pharmacopoeia in 2017?

The monograph for Water for Injections was revised to allow production by methods other than distillation, such as reverse osmosis coupled with other techniques, provided the process is validated and monitored. Before that, European WFI had to be distilled, while the USP had allowed membrane methods for longer.

How does a two-pharmacopoeia site specify its water system?

To meet both monographs, which are now largely aligned on limits, and to satisfy both regulators' expectations for validation and monitoring. Where the two differ in detail, the stricter reading is applied.

What extra monitoring does membrane WFI need?

Continuous monitoring of conductivity and total organic carbon, close attention to microbial control and endotoxin, and validated sanitisation, because a membrane system lacks the thermal barrier a still provides. Regulators expect a stronger control strategy for membrane WFI.

How is a WFI storage tank designed?

With a hydrophobic vent filter that is heated or integrity-tested, a spray device that keeps the tank's headspace and walls wetted, a rupture disc or relief, sanitary connections and no dead space at the outlet, so that the stored water stays at loop quality. The tank is part of the loop and is designed to the same standard.

How is Purified Water different from Highly Purified Water?

Highly Purified Water was a European grade with WFI-like limits made by non-distillation methods; it was withdrawn from the European Pharmacopoeia once membrane WFI was permitted. Sites with older specifications referencing it update them to WFI.

What is a user requirements specification and who writes it?

The document stating what the water system has to deliver, in quality, quantity, points of use and regulatory expectation, written by the owner's engineering and quality organisation before design starts, and traced through the qualification afterward. A European parent expects to see it first, and it is the basis for every later acceptance.

What materials and finish do the two frameworks expect?

Both accept 316L stainless with appropriate finish and passivation, orbital welds with documentation, and slope and drainability. ASME BPE is the usual reference in the US, and European sites accept it with their own additions on documentation.

How is ozone used in ambient WFI loops?

Ozone dissolved in the storage tank and destroyed by ultraviolet before points of use provides continuous microbial control without heat. It requires ozone-compatible materials and validated destruction, and it is increasingly used where energy cost matters.

How does South Carolina's climate affect the water system?

Warm feed water in summer raises RO productivity and microbial risk together, and the pretreatment and sanitisation regime are designed for the summer condition. Seasonal variation is covered in the performance qualification.

What about water for the automotive and aerospace plants here?

Industrial deionised water for painting and processing, which is a different specification and does not carry pharmacopoeial requirements. Where a site has both regulated and industrial water, they are separate systems.

How is water quality instrumentation qualified for two pharmacopoeias?

By selecting conductivity and total organic carbon instruments that meet both compendia's requirements, calibrating them against traceable standards, and documenting the calibration and the system suitability tests each pharmacopoeia describes. The instruments have to satisfy the stricter of the two, and their records have to show it.

What documentation does a European parent expect at handover?

Material certificates, weld documentation, passivation records, calibration certificates, qualification reports and a monitoring plan, organised so that traceability from specification to installed system is complete. The structure is agreed before fabrication.

How is endotoxin controlled in a membrane WFI system?

By ultrafiltration at the end of the generation train, by microbial control throughout, and by monitoring. The absence of a still means endotoxin control depends on the membrane stages and the sanitisation regime.

Can an existing Purified Water system be upgraded to WFI?

Sometimes, by adding ultrafiltration and additional membrane stages and by strengthening monitoring and sanitisation, if the existing loop design and materials support WFI. The assessment is done before committing.

What is the commonest water system question from European parents here?

Whether membrane WFI is acceptable to them, and what control strategy they expect for it. Settling that early decides the generation train, the loop design and the qualification scope.

Specifying a South Carolina water system for two regulators?

Tell us which markets your product reaches and we will tell you what that costs in water system terms. Call 201-450-8280 or use the form below.

Service needed *