No, according to the CanadaGAP Food Safety Manuals it is not acceptable for employees to carry drinking water with them into the production site when they are working because of the potential for cross-contamination (e.g., mouth to hands to product).

This requirement is outlined in Form C (Employee Personal Hygiene and Food Handling Practices Policy – Production Site) of the CanadaGAP manual. Employees need to wash their hands each time after having a drink of water.

If an operation would like to allow employees to carry drinking water, they must first mitigate the food safety risks associated with this practice. Within the CanadaGAP program allowances can be made for operations to do something different from what is laid out in the manual. These are called deviations. This process is explained in “How to Complete the Manual” under the important note where it states:

The requirements along with their procedures were determined based on food safety risks that may be present in an operation. If the hazards are not controlled, there is potential for contamination of the product. To mitigate the risks the procedures need to be followed. However, deviations from these procedures are possible and may be acceptable in completing the requirement. There may be a variety of ways to meet the requirements and still mitigate risk. An operation may choose to implement different procedures than those contained in the manual and these may be acceptable to satisfy program requirements. A risk assessment would need to be completed (see Appendix U:  Introduction on How to Assess Risk – with examples). Procedures would need to be carefully developed to ensure the hazards are controlled, and thoroughly documented to ensure the procedures are followed consistently. If this approach is taken the effectiveness of those procedures will have to be assessed during an audit. It will be up to the certification body to determine if procedures different from those provided in the manuals are acceptable or not.

Therefore, the operation would have to implement different procedures to mitigate the food safety risk. For this scenario, the operation would have to have procedures in place to mitigate the potential for cross-contamination from mouth to hands to product. There may be various ways to mitigate the risk. An example could be a procedure where the operation allows only water bottles that have a non-removable lid and contact from hands is not required to open and close the bottle (see examples below). This procedure would need to be clearly documented and employees trained accordingly. It would be up to the certification body to determine if this deviation was acceptable.

Water bottles that would NOT be acceptable Water bottles that COULD be acceptable with written procedures on how to appropriately use the water bottle.

NOTE: employees need to be trained on the proper procedures to ensure that hand to mouth contamination does not occur (for example, Gatorade bottle needs to be opened with mouth/teeth, purple bottle needs to always be ‘popped’ open, etc.).


December 9th, 2021 at 04:29 pm