Water (for fluming and cleaning) and Ice

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.

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 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.

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.

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).

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.