General Water Testing
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.
A composite water sample is ONE sample which is made by combining water samples from two or more sources/uses/locations. For example, an operation uses two wells, one well is used for handwashing and the other well for filling their dump tank. Instead of taking two separate samples for each well, only ONE sample is taken which is a mixture of water from both wells.
Composite water testing is allowed. The way in which operations choose to sample the water is up to them. As long as operations are taking the appropriate number of samples, from the appropriate place, at the appropriate time, etc. the sampling method is up to them. However, if they receive a positive result (i.e., more than 0 total coliforms and 0 E. coli) they will not know which source (or multiple sources) has the problem, and will have to do more investigation and testing to determine the source of contamination. More information about composite water testing can be found in Appendix G.
Yes it matters. Final rinse water must be taken from the final rinse equipment: this will determine if the rinse equipment is clean (unless a hose is used to rinse product; then the sample may be taken from the water source) when testing for potability.
Additionally, some other activities like post-harvest agricultural chemical application, and humidity and misting require that water tests are taken from the equipment to ensure that the equipment is not a source of contamination, Treated water needs to be taken from where it is being treated to ensure it is being treated appropriately. Water 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 other uses (e.g., to fill ponds, dump tanks, handwashing, etc.) needs to be taken from the appropriate location (e.g., equipment, tap, storage cistern/tank/container, etc.).
IN ALL CASES operations should refer to the manual to ensure all relevant factors are being considered. There are many different water sources (e.g., municipal, well, surface), uses (e.g., washing, fluming, hydrocooling, etc.) methods (e.g., submersion, spray nozzles, etc.) and water variations (e.g., closed circuit pipes, storage in tanks, treatments, etc.) that need to be assessed. The requirements/procedures will be specific to each unique situation.
Does documentation need to be obtained proving that the laboratory used for water testing uses appropriate sampling and testing methods to perform analyses in accordance with the applicable requirements of ISO/IEC 17025 standards?
No. The CanadaGAP manual [in various sections such as 15.1 (Water Assessment)] does not require the operation 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.
To determine if the lab uses appropriate sampling and testing methods to perform analyses in accordance with the applicable requirements of ISO 17025: Check 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).
It depends on their water uses and what is being done to the water. If water is used for a final rinse, then it needs to be tested, as the result is used to see if the equipment itself is clean. If water is treated, then it must be tested to determine that the treatment is working. If water is stored, then it must be tested to ensure that the storage vessel is not a source of contamination. If water is being used for humidity/misting or post-harvest applications of agricultural chemicals, it must be tested from the equipment itself to ensure it is clean. Otherwise, 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 operation must take appropriate corrective action (e.g., use alternate source, treat water, test water, etc.).
For countries other than Canada, refer also to the next question.
In Canada, municipal water is assumed to be potable.
The glossary definition of “potable water” according to the CanadaGAP Food Safety Manuals is:
- 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).
Municipal water potability is ensured and maintained by the municipality in Canada. Therefore, testing is not required under the CanadaGAP program unless the water is stored, treated, recycled/recirculated, or used where a test is required from the equipment.
However, in other countries, municipal water potability parameters may not be the same as the CanadaGAP requirements stated above. In these cases, the expectation would be for the municipal water to be tested to ensure it meets the CanadaGAP requirements for potable water.
In some provinces, the provincial standards for potable water are different from the CanadaGAP requirement of 0 total coliforms and 0 E. coli. Does an operation have to meet the CanadaGAP requirement (which is the same as the microbiological parameters in Health Canada’s Guidelines for Canadian Drinking Water Quality), or do they follow their provincial standards?
In the manual, it would usually depend on which is the stricter requirement and this would need to be followed. However, in this case nothing is stricter than Health Canada’s Guidelines for Canadian Drinking Water Quality of 0 total coliforms and 0 E. coli. The CanadaGAP requirement must always be followed. If the provincial standard is not 0 and 0, then the requirement within the manual to follow the Guidelines for Canadian Drinking Water Quality supersedes the provincial standard and must be met.
What if a lab is not able to report water test results as 0 total coliforms and 0 E. coli? The lab may only be able to report total coliforms as “less than 10” or “less than 1”. What does this mean, and is it acceptable?
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 a 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 microbiological parameters of Health Canada’s Guidelines for Canadian Drinking Water Quality.
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 Guidelines for Canadian Drinking Water Quality.
If an operation requires potable water/ice do they have to test EACH of their water uses individually?
No. Operations 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 their uses. How the operation chooses to demonstrate this potability is up to them. Depending on their set-up, one sample could show potability for a number of uses. For example, if an operation uses water from the SAME well for handwashing, cleaning of equipment and final rinse they may choose to test each of those individually OR they may choose to test only 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 potable. 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 an operation takes individual tests it will be easy to determine sources of contamination, whereas it won’t be as easy if the final rinse test is being used to show potability of all the sources, and contamination is found in the final rinse water test. The operation will have to do some investigatory work to determine where the contamination is (e.g., the well itself, the final rinse equipment).
If a lab uses a sensitive testing 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 an operation autofail an audit?
It depends on what the water is used for. Review the Water (for Fluming and Cleaning) and Ice section within the CanadaGAP audit checklist. Water uses highlighted in yellow in question L3A of the audit checklist will result in an autofail if at least one good (0 total coliforms, 0 E. coli) water test is not available.
Water used on Product
If an operation 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?
Yes. All five lines must show potability. If the fifth line is not tested the operation will have no idea if that water is potable. The scoring is based on ALL water uses being successfully tested. The operation didn’t test one of them and that fifth line is used to determine the score – it is an AUTOFAIL.
If an operation involved in packing/repacking has municipal water and is final rinsing product, does the water need to be tested?
An operation that is packing/repacking 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.
If an operation 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?
Yes. The contamination might be in the final rinse equipment itself so each line needs to be tested.
An operation producing and packing potatoes for processing uses water to flume, wash and final rinse potatoes. Water is also used to clean the packing line and for hand washing. Does this operation need to test all of these water uses?
No. Potable water is not required for any uses in an operation handling potatoes for processing EXCEPT for hand washing. The only water test needed is of water used for hand washing. However, if hand sanitizer is used after hand washing (and drying with paper towel), then potable water is not required. This means the operation would not have to do ANY water tests.
Operations that wash leafy greens and herbs have strict requirements in regard to maintaining water potability. Why is this? Can CanadaGAP provide further guidance to meet these requirements?
Please consult the following document Expectations for Post-Harvest Water Used in Leafy Green and Herb Field Operations for more information on the risks and outbreaks associated with these commodities, an outline of the CanadaGAP requirements, and possible resources to help meet the requirements.
Water for Cleaning Buildings, Equipment and Containers
Does water used for washing the inside of buildings (e.g., walls, floors, etc.) have to be tested for potability?
Section 15.1 (Water Assessment) states that the person responsible uses potable water for cleaning buildings, equipment, containers, etc., and that the water sample is taken from the appropriate location (e.g., equipment, tap, storage cistern/tank/container, etc.). Therefore, the testing requirements (as per Section 15.1/15.2/15.3) would depend on where the water comes 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 that uses appropriate sampling and testing methods to perform analyses in accordance with the applicable requirements of is ISO/IEC 17025 standards. The exception to this requirement is for operations growing potatoes for processing: potable water is not required for cleaning of buildings, equipment, containers, etc.
Water used for Handwashing
An operation involved in packing/repacking uses water for hand washing BUT they also have hand sanitizer. Do they need to test this water?
No. If hand sanitizer is used after hand washing (and drying with paper towel), then potable water is not required.
If an operation has portable toilets that are equipped with hand washing facilities (water reservoir, soap and paper towels) do they still need a water test(s) of the portable toilet hand washing water?
It depends on the option for hand washing that the operation has chosen. There are three options available:
1) hot and/or cold running potable water (with a receptacle to collect wastewater), soap and disposable paper towels
2) water (with a receptacle to collect wastewater), disposable paper towel to dry hands and hand sanitizer
3) hand wipes and hand sanitizer.
If option 1) is chosen then the water is required to be potable and this potability must be confirmed. Section 11.1 of the manual states that hand washing water stored in permanent tanks (e.g., within portable washrooms or as standalone facilities) is NOT considered potable UNLESS:
“- the water is tested each time the tank is filled to confirm potability, OR
– the water is treated and tested to confirm potability is being maintained with treatment as per procedures in Section 15.3 Treatment, OR
– the cleanliness of the tank is maintained, filling procedures are followed and the water is tested to confirm potability as per procedures in Section 15.2″
If option 2 is chosen, then the water is not required to be potable; 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 is not necessary as water is not used.
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