General Water Testing
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? Prior to use water test – acceptable sampling window: Apr 26 – June 24. |
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 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). |
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.
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 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 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.
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).
Water used on Product
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.
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.
Yes. The contamination might be in the final rinse equipment itself so each line needs to be tested.
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.
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
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
No. If hand sanitizer is used after hand washing (and drying with paper towel), then potable water is not required.
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
OR
2) water (with a receptacle to collect wastewater), disposable paper towel to dry hands and hand sanitizer
OR
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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