Q. A producer has one well that provides water to their employees’ bunkhouse as well as to the hand washing facilities. Will the pre-season water test result from the bunkhouse be acceptable to show the potability of the water source?
A. Yes, water testing of the well taken from the bunkhouse would be acceptable unless the water is being used for a final rinse of product. If there is a final rinse (or recirculated water is being treated for potability) then the test needs to be taken from the rinse equipment or after treatment.
Q. Can a producer irrigate with production wastewater? This issue is starting to come up in areas where there is not a lot of water available for irrigation, so re-using production wastewater is being considered an option. Some use drip irrigation – which is okay, but what about overhead?
A. The manual does not say that production wastewater cannot be used. Section 10 says "Producer/storage intermediary/packer disposes of production wastewater in a manner that prevents contamination of packaging materials, product, water sources, compost and other by-products". Section 7 says that producers have to assess the water and determine if it could be a source of contamination. Production wastewater could be a source of pathogens or chemical contamination (especially if the water is being chlorinated). So the producer would have to show somehow that it is not a source of either of these, which would most likely mean testing.
Q. If a packer has municipal water and is rinsing product, does he need to test the water?
A. The packer still needs two water tests per year from the final rinse nozzles. This is because the rinsing equipment (i.e., nozzles) itself might be contaminated.
Q. If the auditee has portable toilets that are equipped with hand washing (water reservoir, soap and paper towels) do they still need a water test of the portable toilet hand washing water?
A. It depends on the option for hand washing that the producer/packer has chosen. There are three options available:
1) hot and/or cold running potable water (with a receptacle to collect wastewater), disposable paper towels, soap and a garbage container
OR
2) water to remove soil from hands (with a receptacle to collect wastewater), paper towel to dry hands, hand sanitizer and a garbage container
OR
3) hand wipes, hand sanitizer and a garbage container
If option 1 is chosen then the water is required to be potable and yes, water testing is necessary. The reservoirs for hand washing water found in portable toilets would be considered under Section 15.2 Storage. These would be tanks or containers for storing water. Regardless of the source – at least twice annually - the producer or packer needs to test the water from the cistern/tank/container using an accredited lab. Documentation from the portable toilet rental company that the water is potable would also be acceptable in place of the tests. Most portable toilets say however that the water is not potable; therefore, sanitizer may be the best option, which would make water testing unnecessary.
If option 2 is chosen then the water is not required to be potable and therefore a test is unnecessary BUT they would need hand sanitizer to go with the water and paper towels.
If option 3 is chosen water testing would not be necessary as water is not required.
Q. Does the producer or packer need to provide documentation to prove that the laboratory used for water testing is accredited to ISO 17025 standards?
A. No. The manual (in various sections such as 15.1 Water Assessment) does not require the producer/packer to obtain a record to prove the accreditation of the lab. The only record referenced in both the manual and the audit checklist is the actual water test result itself. As an auditor, you need only to see the records listed in the middle column of the audit checklist. To assess whether the lab is accredited, you can ask the producer open questions such as “who is the lab accredited by?” “To what standard are they accredited?” “How do you know if the lab is accredited?” It is also a good idea to know ahead of time which laboratories are accredited to ISO 17025 in the areas you audit. This can be done by checking the lab’s website or the website of accreditation bodies such as the Standards Council of Canada (
www.scc.ca) or the Canadian Association for Laboratory Accreditation (
www.cala.ca).
Q. Does water used for washing the inside of buildings (e.g., walls, floors, etc.) have to be tested for potability?
A. Section 15.1 Water Assessment states that the producer/storage intermediary/packer uses potable water for cleaning buildings, equipment, containers, etc. The testing requirements (as per Section 15.1/15.2/15.3) would depend on where the producer/storage intermediary/packer gets the water from right before it is used for cleaning (e.g., from a municipal tap, from a private well tap, from a storage tank/container, from a treated tank, etc). For example, municipal water from the tap would not have to be tested but if that same water was stored in a tank it must be tested twice annually using a lab accredited to ISO 17025 standards. The exception to this requirement is for producers growing potatoes for processing: potable water is not required for cleaning of buildings, equipment, containers, etc.
Q. In my province, the provincial standards for potable water are different from the CanadaGAP requirement of 0 total coliforms and 0 E. coli. Do I have to meet the CanadaGAP requirement (Canadian Drinking Water Standard), or do I follow my provincial standards?
A. Usually it would depend on which is the stricter requirement and this would need to be followed. However, in this case you cannot get stricter than the Canadian Drinking Water Standard of 0 total coliforms and 0
E. coli. If the provincial standard is less than 0 and 0, then the requirement within the manual to follow the Canadian Drinking Water Standard supersedes your provincial standard and must be met.
Q. What if my accredited lab is not able to report the test results as 0 total coliforms and 0 E. coli? The lab told me that they can only report total coliforms as "less than 10" or "less than 1". What does this mean, and is it acceptable?
A. When water test results are reported as <10 total coliforms per 100mL of water or <1 total coliforms per 100 mL of water, this is based on the sensitivity of the testing method and the dilution rate used in the accredited lab. The lab can only detect results to <10 or <1 total coliforms per 100mL of water; they cannot give a more specific reading. This essentially means that no organisms were found in the test but there is a possibility that if a larger sample were used (1000 mL vs. 100 mL of water) they may have found something.
Results reported this way are acceptable and the water is considered potable.
If your accredited lab uses the method where they can actually give a number under 10 (e.g., 7 total coliforms), then results above 0 are not acceptable and the water is not potable based on the Canadian Drinking Water Standard.
The lab must report total coliforms using one of these two options (i.e., either an exact number such as 5, OR a "less than" count). It is not acceptable for the lab to report the results simply as “acceptable” or “negative”, since this prevents comparing the value to the Canadian Drinking Water Standard.
Q. If my accredited lab uses the more sensitive method (i.e., reports an exact number of total coliforms) and the water test results are not 0 total coliforms and 0 E.coli, will I autofail the audit?
A. It depends on what the water is used for. Review the Water (for Fluming and Cleaning) and Ice section question #3 within the audit checklist. Water uses highlighted in yellow will result in an autofail if at least one good (0 total coliforms, 0
E. coli) water test is not available.
Note: All of the questions found in Q1. below pertain to the OFFS Audit Checklist Version 5.1 – Water (for Fluming and Cleaning) and Ice (refer to Sections 15 and 16), Question 3
Q1a. How is an auditor supposed to fill out the chart in the left hand column?
A. An auditor begins by determining which water uses a producer/packer has in their operation by either checking or not checking off the N/A box. Once this is done they will know which water uses require water tests. They need to then see the water tests results for these uses and check off the appropriate boxes to show if they were completed or not.
Q1b. Does a producer/packer have to test EACH of their water uses individually?
A. No. Producers/packers must show that ALL of their water uses are potable. The only way to do this is to take a water sample test, but this doesn’t mean they have to individually test all of them. How they choose to show this potability is up to them. Depending on the producer/packer’s set-up, one sample could show potability for a number of uses. For example if a packer uses water from the SAME well for handwashing, cleaning of equipment and final rinse they may chose to test each of those individually OR they may only chose to test the final rinse water.
By testing only the final rinse water they can determine if the final rinse equipment is clean AND if the well supplying the handwashing water and water for cleaning of equipment is okay. In this case, the requirement for potable water could be met by testing only the final rinse equipment. Individual tests are another option and would accomplish the same thing.
If they take individual tests it will be easy to determine sources of contamination, but it won’t be so easy if contamination is found in the final rinse water test. The producer/packer will have to do some investigatory work to determine where the contamination is (e.g., the well itself, the final rinse equipment).
Q1c. When are the 2 samples required for water testing to be taken? Does it matter?
A. Yes it matters. The first sample is to be taken prior to use and the second sample during the season. “Prior to use” means BEFORE the water has come into contact with the product intended for sale (e.g., to packer, customer, etc.), is used to clean buildings, equipment and containers, and/or is used for handwashing. Producers/packers must ensure they have potable water before they use it or they are risking contamination of their product, hands, equipment, buildings and containers. The second test can be taken anytime during the season to ensure that contamination hasn’t occurred and that potability is being maintained. It is recommended that this is done again mid-season but the decision to take the sample will depend on length of season, deviations (e.g., risks to water sources, changes to the operation), practices used, etc.
Q1d. Where are the water sample tests supposed to be taken from? Does it matter?
A. Yes it matters. Final rinse water must be taken from the final rinse equipment. This will determine if the rinse equipment is clean. Treated water needs to be taken from where it is being treated to ensure it is being treated appropriately. Water that is being stored (e.g., in a container, tank, cistern) needs to be taken from where it is being stored to ensure that it is clean. Water used for all other uses (e.g., to fill ponds, dump tanks, handwashing, etc.) can be taken from the point closest (generally a tap) to the source.
Q1e. If a producer/packer has multiple packing lines each with a final rinse and only one well sourcing them all, do they need to test each packing line’s final rinse water?
A. Yes. The contamination might be in the final rinse equipment itself so each line needs to be tested.
Q1f. What is a composite water sample? Are these allowed in the CanadaGAP program?
A. A composite water sample is ONE sample which is made by combining water samples from two or more sources/uses/locations. For example a packer uses 2 wells, one well is used for handwashing and the other well for filling his dumptank. Instead of taking 2 separate samples for each well he takes only ONE sample which is a mixture of water from both wells.
Yes, this is allowed. The way in which producers/packers choose to sample the water is up to them. As long as they are taking the appropriate number of samples, from the appropriate place, at the appropriate time, etc. the sampling method is up to them. It must be kept in mind though that if they receive a positive result they will not know which well (or both) has the problem, and will have to do more investigation and testing to determine the source of contamination.
Q1g. A packer ONLY uses municipal water. Do they need to have any of their water tested?
A. It depends on their water uses and what they do to that water. If they use it for final rinse, then yes, it needs to be tested as the result is used to see if the equipment itself is clean. If they treat the water, then they must test it to determine that the treatment is working. If they store that water they must test it to ensure that the storage vessel is not a source of contamination. Otherwise, no, a test is unnecessary; it is assumed the municipality is doing its job providing potable water. If the municipality advises of an adverse water event, this is treated as a deviation and the producer/packer must take appropriate corrective action (e.g., use alternate source, treat water, testing, etc).
Q1h. A packer uses water for hand washing BUT they also have hand sanitizer, do they need to test this water?
A. No. If hand sanitizer is used after hand washing then potable water is not required.
Q1i. A processing potato producer/packer uses water to flume, wash and final rinse his potatoes. He also uses water to clean his packing line and for hand washing. Does he need to test all of these water uses?
A. No. Potable water is not required for any uses in a processing potato operation EXCEPT for hand washing. The only test he needs to do is of the water used for hand washing. If hand sanitizer is used after hand washing, then potable water is not required. This means he would not have to do ANY water tests.
Q1j. What does all of the yellow highlighting mean?
A. The yellow highlighting shows the water uses where if NO water tests for potability have been completed, the producer/packer will AUTOFAIL the audit.
Q1k. How does the scoring chart work? Can part marks be given?
A. Both charts (one out of 10 points and the other out of 8 points) work the same way, except for the autofail as explained above in Q1j. Use the Yes/No guidance in the charts to determine the scoring.
In the first chart (out of 10 points):
The producer/packer must provide the auditor with results from two tests that show potability for each water use. Each test is worth 5 marks. The marks are not for how many uses/sources the operation has. For example if the producer/packer has 2 wells which would require 2 tests each, the tests are NOT worth 2.5 each. Instead, overall compliance with the requirement is scored. Each well is considered in turn. If they have tested the first well twice at the appropriate times but they have not tested the second at all, they will AUTOFAIL because one of their water uses is not proven potable. They have not met the program requirement to show potability for all water uses.
If they had tested the first well twice at the appropriate times and only tested the second well prior to use, they would score 5/10. They would NOT get 7.5 points. The marks are allotted based on completing testing for ALL of the water uses. The scoring is determined by the tests not completed (unless of course they have all been done appropriately).
In the second chart (out of 8 points):
As in the first chart, the producer/packer must provide the auditor with results from two tests that show potability for each water use. Each test is worth 4 marks. If no testing at all has been done on one (or more) of the water uses, the score is 0. Follow the Yes/No guidance in the chart to determine the scoring.
Q1l. If a producer/packer has five packing lines each with a final rinse and only one well sourcing them all, will they still autofail if they only test four of the final rinse lines?
A. Yes. All five lines must show potability. If the fifth line is not tested the producer/packer will have no idea if that water is potable. The scoring is based on ALL water uses being successfully tested. The producer/packer didn’t test one of them and that fifth line is used to determine the score – it is an AUTOFAIL.