Water (for fluming and cleaning) and Ice

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

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 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).