Record of Decision : Water Analysis Requirements for Fresh Fruit and Vegetable Registered Establishments

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October 2010

Submitted to
Fresh Fruit and Vegetable Program

Product or Subject

Water Analysis Requirements for Fresh Fruit and Vegetable Registered Establishments

Question or Description of Problem

Does a Registered Produce Warehouse (RPW) have to provide the Canadian Food Inspection Agency (CFIA) with a complete water analysis indicating microbiological analysis as well as the chemical analysis (including heavy metal content) for the water used at the facility? At what frequency would these tests have to be conducted?

Decision

Please note that it is assumed that the usual source of water for fresh fruit and vegetables packing operations is either ground (well) water and/or municipal water.

Intent of Implementing a Water Quality Testing Program

The water quality testing program implemented by the operator should be designed with the intent of preventing potential contamination of fresh fruit and vegetables by a contaminated water source (see Definitions and Scope of Fresh Fruit and Vegetables covered under the CFIA FFV Program for definition of fresh fruit and vegetables).

The establishment shall be supplied with potable water (cold and hot) that meets the guidelines for potability published in Health Canada's Guidelines for Canadian Drinking Water Quality and any applicable provincial, municipal and territorial water requirements. Only potable water shall be used for the final rinsing of produce.

Water other than potable water may be used for fire protection or auxiliary services, including the washing of soil from raw produce and the fluming of raw produce, if there is no connection between those systems and the system for potable water.

Microbiological analysis

Prior to establishment registration and at the time of renewal, satisfactory microbiological analysis results of water used within the establishment are provided by the operator.

  • Analysis must be performed not more than six months prior to the date of application for registration (initial registration and/or renewal).

Suitable sites for sampling could include water fountains, hand-washing stations and points of use, such as hoses. Samples of water must be tested for total coliform bacteria and Escherichia coli. Additional testing may be required if there are changes to source water, piping systems, or if there are suspected contamination issues.

Microbiological guidelines

  • Total coliforms: maximum acceptable concentration (MAC) is 0 per 100 mL.
  • Escherichia coli: maximum acceptable concentration (MAC) is 0 per 100 mL.

Chemical analysis

Prior to establishment registration, satisfactory chemical analysis results of water used within the establishment are provided by the operator.

Suitable sites for sampling could include water fountains, hand-washing stations and points of use, such as hoses.

At a minimum, samples of water should be tested for antimony, arsenic, cadmium, chromium and lead. Additional testing may be required if there are changes to source water, piping systems, or if there are suspected contamination issues.

Chemical guidelines

  • Antimony: maximum acceptable concentration (MAC) is 0.006 mg/L
  • Arsenic: maximum acceptable concentration (MAC) is 0.01 mg/L
  • Cadmium: maximum acceptable concentration (MAC) is 0.005 mg/L
  • Chromium: maximum acceptable concentration (MAC) is 0.05 mg/L
  • Lead: maximum acceptable concentration (MAC) is 0.01 mg/L

Unsatisfactory Results

If results of microbiological and/or chemical analysis are found to be unsatisfactory, the establishment should contact its provincial environmental authority and/or public health unit for assistance and notify the regional CFIA office. The establishment should conduct root-cause analysis to guide identification and implementation of corrective action(s). Water testing frequency should be increased to verify that the source of contamination has been eliminated.

Records

The establishment should:

  1. Maintain appropriate water testing records that specify water source(s), sampling site(s), analytical result(s), analyst(s) and date(s).
  2. Use a private laboratory for water testing that is accredited by an internationally recognized accrediting body such as the Standards Council of Canada (SCC) or the Canadian Association for Laboratory Accreditation (CALA) or, if possible, use municipal or provincial government laboratories for water testing.

At the time of the registration or monitoring inspection, CFIA staff is to verify that:

  1. Water testing records are available on file, complete, and appropriate to meet potablity requirements;
  2. The establishment is using an appropriate (i.e., accredited) laboratory to test their water samples;
  3. Any corrective actions taken have been effective (e.g., in response to an unsatisfactory result or boil water advisory).

For assistance verifying any of the above, CFIA staff should consult with the Area or a National Fresh Fruit and Vegetable Specialist.

Rationale

Legal Authority

Part X of the Fresh Fruit and Vegetable Regulations deal with the Registration of Establishments and Operation and Maintenance of Registered Establishments.

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1) l) Every registered establishment that is a building shall be supplied with potable hot and cold water that is protected against contamination and is adequate in quantity and pressure to serve the water needs of the establishment.

2) In a registered establishment, water other than potable water may be used for fire protection and auxiliary services, including the washing of soil from raw produce and the fluming of raw produce, if there is no connection between the system for that water and the system for potable water.

In addition, Part I.1 of the Regulations establishes general food safety requirements for all produce marketed interprovincially and/or in international trade.

3.1

1) Subject of subsection 2), no person shall market produce in import, export or interprovincial trade as food unless it
e) is prepared in a sanitary manner;

4) For the purposes of paragraph 1) e), prepared in a sanitary manner includes preparation in such a manner that
a) no stagnant or polluted water is used in the washing or fluming of the produce;
b) only potable water is used in the final rinsing of the produce to remove any surface contaminant before packing;
c) the final rinse water, if reused, is used only in the initial washing or fluming of the produce;

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4) Operations in relation to the preparation of produce in a registered establishment shall be carried out in a sanitary manner.

For establishments that are registered under the Canadian Partner in Quality (C-PIQ) Program, the authority is provided through signing of a Participation Agreement. As such, C-PIQ establishments must comply with Appendix A of the C-PIQ Program Manual, in addition to Part I.1 of the Fresh Fruit and Vegetable Regulations.

Additional Resources

Canadian Association for Laboratory Accreditation Inc. (CALA)
Canadian laboratories accredited by the Standards Council of Canada (SCC)
Health Canada's Guidelines for Canadian Drinking Water Quality
Safe Water for Food Processing

Last Update : May-June 2012

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