If water is taken into a production site to pre-wash a product (i.e., product is being immersed in a container/bin/tank of water), is this considered ‘water for washing/cooling product’ or ‘storage water’? For example: an operation with harvested carrots takes an open container/bin/tank of water into the field. After harvesting, the carrots are immersed in the water for pre-washing/cooling.

This pre-washing/cooling water being used in the field is considered ‘wash water’ and/or “cooling water” and all of the relevant commodity-specific requirements in Section 15 under the “Water for Hydro-cooling, Cooling, Fluming and Washing Product” section should be followed.

The requirements are as follows:

• Water used to fill or replenish flumes, hydro-coolers, dump tanks, buckets, drums or pits is from a potable source
• Water used for fluming, washing, cooling, or hydro-cooling is kept potable if this is the final water in contact with product (i.e., there is no final rinse)

If the water in the container/bin/tank was NOT kept potable:

The operation would then need to follow the requirements in Section 15: ‘Final Rinse Water’:

• If water used to cool, hydro-cool, flume, or wash product has not been kept potable, the person responsible provides a final potable water rinse

If the carrots were immediately going into storage, the operation would need to provide this final rinse before storage. This is important because the poor-quality pre-washing/cooling water may contain microorganisms that could grow and proliferate during storage. Since packing of these carrots may not occur until weeks or months later, the operation cannot rely on the final rinse that will occur during packing to mitigate the risks associated with this poor-quality pre-washing/cooling water.

If the water in the container/bin/tank WAS kept potable:

The operation does not need to provide a final rinse before storage.

Regardless of if the pre-washing/cooling water is kept potable or not; if the carrots are not going into storage and packing happens shortly after harvest, the operation will only be required to do the final rinse that occurs during packing.

This water is NOT considered stored water, therefore the water storage requirements in Section 15.3 do not apply. These containers/bins/tanks are not water storages, rather a piece of production site equipment used to facilitate this pre-washing process. The requirements for production site equipment should be followed.