If two tests are required to show potability of water, does it matter when they are taken?

Yes, it matters. The first sample is to be taken after the operation’s start date but prior to use of the water, and the second sample is to be taken some time during the season. The intent of this requirement is to reduce the risk of product contamination by ensuring the water is potable before it is used, and that potability is maintained throughout the season.

As per the glossary definitions:

“Start Date: This is Day 0 for an operation. Nothing has occurred yet. NOTE: Water tests need to be taken after the start date.”

“Prior to use: 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.”

“Potable water: Water that meets the parameters under the Canadian Water Quality Guidelines for Drinking Water Quality (biological parameters are 0 Total Coliforms and 0 E. coli).”

Operations must first identify their Start Date and record it at the beginning of their CanadaGAP Food Safety Manual under “Operation Information”. Year-round operations that have no pause/break in activities throughout the year should chose a Start Date that best fits their process(es) and water use(s).

Next, the operation must identify the following information:

• all water sources used (i.e., municipal, well and/or surface water)
• the internal water systems in place (e.g., storage tanks, water treatment, recirculation systems, washing/rinsing equipment, etc.)
• how the water is used (e.g., cleaning, hand washing, final rinse, hydro-cooling, etc.)
• when each water use will begin

This information should be recorded on Form F. Water (for Fluming and Cleaning) Assessment.

Now that the start date and first use date have been established, the operation can determine when and where to take the prior to use water sample(s). They should keep in mind the criteria in place (after the start date but prior to use AND not earlier than 60 days from first use). For year-round operations, since there is continuous water use, they need to take the prior to use sample immediately after their chosen start date.

Note: If composite sampling is being used for multiple water uses, it is important to pay attention to the ‘first use’ dates. If the ‘first use’ dates of the individual water uses are greater than 60 days apart, composite sampling cannot be used.

The second water sample can be taken anytime during the season to ensure that contamination hasn’t occurred and that potability is still being maintained. It is recommended that this is 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 process or equipment, etc.), practices used, etc.

In order to meet the requirements, the test results must confirm the water is potable. If the results indicate water is not potable, the operation is required to implement corrective actions and to retest the water to confirm the actions taken corrected the problem.

It is recommended the water tests are completed mid way through the acceptable sampling window to avoid exceeding the 60 days prior to use period in case the predicted schedule changes, and to allow time for corrective actions implementation and retesting if needed.

Water test timing examples