Water (for fluming and cleaning) and Ice2017-11-16T13:21:05-05:00
General Water Testing
Water used for Ice
Water Used on Product
Water Used for Handwashing
Water for cleaning buildings, equipment and containers

General Water Testing

If two tests are required to show potability of water, does it matter when they are taken?2023-05-04T09:51:26-04:00

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

Example 1: An operation produces blueberries. On Mar 18, the operation applied an agricultural chemical, which is the first agronomic activity for the current season. Well water is used for cleaning the production site equipment and the water is not treated or stored. The producer predicts the berries will be ready for harvest the first week of July. Each year the harvester machines are washed on June 25. The blueberry season runs until mid September.

Based on the known information and the predicted season what would the water test plan look like?
Start date: Mar 18
First use: June 25
End of season: Sept 10-20
Water source: well water (not treated or stored)
Water use: cleaning of equipment

Prior to use water test – acceptable sampling window: Apr 26 – June 24.
Recommended sampling date May 24.
During season water test (second water test) – acceptable sampling window: July 1 – Sept 15. Recommended sampling date Aug 15

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.

Start Date: August 1
First use: ongoing
End of season: July 31
Water source: well water (not treated or stored)
Water use: water for handwashing

Prior to use water test: Recommended sampling date August 1/2 (year-round operation so sample should be taken right away since the employees are already using the water).
During season water test (second water test) – acceptable sampling window: anytime during the season.
Recommended sampling date – most meaningful indication of the quality of the water supply over time would be to take it a few months after the first sample (e.g., February or March)

May 4th, 2023 at 09:51 am
What is a composite water sample? Are these allowed in the CanadaGAP Program?2023-03-31T11:02:00-04:00

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.

To ensure a true representation of the water being tested, treated water should not be combined with untreated water to form a composite sample, doing so may create a sample that does not truly indicate the potability of the water (i.e. the chlorine in the treated water could react with the untreated water and the composite sample results may show the water to be potable even if it was not).

More information about composite water testing can be found in Appendix G.

March 31st, 2023 at 11:02 am
Where are the potable water sample tests supposed to be taken from? Does it matter?2020-03-31T15:16:58-04:00

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.

March 31st, 2020 at 03:16 pm
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?2021-04-16T14:35:32-04:00

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).

April 16th, 2021 at 02:35 pm
An operation uses ONLY municipal water. Do they need to have any of their water tested?2021-01-06T10:49:30-05:00

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.

January 6th, 2021 at 10:49 am
Is municipal water in other countries considered the same as municipal water in Canada?2020-11-24T14:54:42-05:00

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.

November 24th, 2020 at 02:54 pm
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?2017-11-03T16:25:38-04:00

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.

November 3rd, 2017 at 04:25 pm
If an operation requires potable water/ice do they have to test EACH of their water uses individually?2017-11-03T16:25:40-04:00

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).

November 3rd, 2017 at 04:25 pm

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?2017-11-03T16:25:33-04:00

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.

November 3rd, 2017 at 04:25 pm
If an operation involved in packing/repacking has municipal water and is final rinsing product, does the water need to be tested?2017-11-03T16:25:34-04:00

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.

November 3rd, 2017 at 04:25 pm
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?2017-11-03T16:25:35-04:00

Yes. The contamination might be in the final rinse equipment itself so each line needs to be tested.

November 3rd, 2017 at 04:25 pm
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?2017-11-03T16:25:35-04:00

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.

November 3rd, 2017 at 04:25 pm
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?2023-03-31T11:40:55-04:00

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.

March 31st, 2023 at 11:40 am
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.2023-10-04T14:43:37-04:00

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.

October 4th, 2023 at 02:43 pm

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?2021-04-16T14:52:52-04:00

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.

April 16th, 2021 at 02:52 pm

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?2017-11-03T16:25:31-04:00

No. If hand sanitizer is used after hand washing (and drying with paper towel), then potable water is not required.

November 3rd, 2017 at 04:25 pm
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?2020-03-31T18:59:52-04:00

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.

March 31st, 2020 at 06:59 pm


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November 16th, 2017 at 01:21 pm
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