Yes, it matters. The first sample is to be taken prior to use of the water and the second sample is to be taken sometime during the season.
“Prior to use” means (as per the glossary definition): Before the water is used on product, hands, equipment, packaging materials, etc. for the first time in a season. Results of water testing need to show potability before water is used. The test must be taken as close as possible to the first use of the water, up to a maximum of 60 days before the first use. NOTE: Where there is an event or activity (e.g., maintenance of piping/pumps, leaking storage tanks, changes in colour/odour and/or turbidity, etc.) that may affect the potability of the water and it takes place after testing was completed (e.g., between the time of analysis and production/packing/repacking/wholesale use, etc.), re-testing is performed. NOTE: For year-round operations, two tests must be taken per 365 days.
Operations must therefore ensure they have potable water before it is used or they risk contaminating product, hands, equipment, buildings and containers, or whatever the water will be used on/for.
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 be done mid-season, but the decision when to take the sample will depend on length of season, deviations (e.g., risks to water sources, changes to the operation), practices used, etc.
Both water tests need to be taken after the operation’s start date.
“Start date” (as per the glossary definition): This is Day 0 for an operation. Nothing has occurred yet. This date should be recorded at the beginning of the CanadaGAP Food Safety Manual under “Operation Information”.
In cases where a program participant is operating year-round, a start date must be chosen by the operation. In year-round operations, activity will be occurring prior to the official start date, so the operation should choose a date that best fits with the timing of their water tests.
To determine if water tests have been timed appropriately (i.e., taken ’prior to use’ and during the season) the auditor will look at the operation’s start date and the water uses.
Example 1: An operation is producing blueberries. On May 1 the operation starts their season (with pruning/planting, applying fertilizer, etc.). They only use water to wash their mechanical harvester, and this water comes from a private well. They start harvesting on July 15 and their harvesting season ends on August 31.
In order to determine when their water tests should be, they have to consider the following:
- Start Date: May 1
- Potable water required to clean the harvester – two tests required from the well
- Both water tests have to be taken after their start date (i.e., after May 1)
- The mechanical harvester will first be cleaned on July 1.
- The first test has to be taken ‘prior to use’ (before July 1) and not more than 60 days in advance (i.e., between May 2 and June 30)
- The second test can be taken anytime during the season (i.e., after July 1 and before August 31)
Examples of acceptable water test schedules for this scenario:
- First test – June 5, Second Test – July 31
- First test – June 20, Second Test – August 10
Examples of unacceptable water test schedules for this scenario (either full or partial marks may be removed)
- First test – April 23, Second Test – June 10
- First test – July 2, Second Test – August 15
- First test – June 5, Second Test -June 27
- First test – June 20, Second Test – Sept. 3
Example 2: A large apple storage facility operates year-round. They have chosen August 1 as their start date. They only use well water in their handwashing facilities for their employees.
In order to determine when their water tests should be, they have to consider the following:
- Start Date: August 1
- Potable water required for handwashing – two tests required from the well
- Both water tests have to be taken after their start date (i.e., after Aug. 1)
- The first test has to be taken ‘prior to use’ and not more than 60 days in advance. As this is a year-round operation they would need to take this sample right away (i.e., Aug. 1 or Aug. 2), as it is assumed the employees are already using the water.
- The second test can be taken anytime during the season. As this is a year-round operation, for the sample to be most meaningful it would be best to wait a few months before taking the second sample (e.g., February or March).
In summary, the year-round operation would have a schedule for sampling which would be August and February. Both samples would be taken after the start date of Aug. 1 and would provide a meaningful indication of the quality of the water supply over time.