Water sampling and testing

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It is expected that the following are covered in a documented procedure:

  • Details of responsibility for taking water samples
  • Details of responsibility for reviewing results and taking action as required
  • Training provided to samplers
  • Frequency of sampling
  • Location of sampling
  • Details of testing – what is water being tested for?
  • Triggers for corrective actions
  • Are there procedures in place for ensuring water is potable and does not contain E. coli?
  • Checks to ensure lab results can be readily linked to sampling sites, dates of sampling
  • Check that the external laboratory is NATA accredited for water testing

What chemical/physical limits are used to ensure the water is potable?  As a minimum it is expected that the company will obtain a copy of the annual testing results from the local water authority.

If there is no town water supply, the establishment must conduct chemical testing as per the Australian Drinking Water Guidelines.

Where non-potable water and/or recycled water is present, it must be clearly labelled and identified and included in site procedure.

The use of non-potable and/or recycled water must have undergone a risk assessment and be covered by appropriate procedures. Risk assessment should indicate the nature of the water and in what circumstances it can be used.

For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.

The water used in your establishments may come from a number of sources, depending on your location. It could be sourced from town water, through a commercial water supplier, from a dam or a river, from rainwater, bore water or even from water which has been reclaimed from your milk products.

No matter where your water has been sourced from, the Export Control (Milk and Milk Products) Rules 2021 Chapter 5 (section 5-4), requires that water used for processing or potential food-contact activities be potable.

You must explain in your documented procedures how you will determine the potability of water used at your site. If you use town water, you can obtain annual or quarterly water quality reports from your local water authority to confirm the water meets the required chemical and physical properties.

If you use non-town water, you will need to treat your water to make it potable. You may achieve this through a number of known processing methods including filtration, heat sterilisation, high pressure sterilisation, UV sterilisation, reverse osmosis, chlorination, or a combination of the above. Regardless of how you achieve potability, you must have a documented procedure in place to ensure the treated water is potable , and follow a water testing program to verify that the chemical and physical properties of the treated water are in accordance with the Australian Drinking Water Guidelines.

The relevant local water authority should be able to supply you with their annual water reports for physical and chemical test results. If not, you must ensure your water meets the requirements outlined by the Australian Drinking Water Guidelines or your local state requirements. You will need to provide evidence to verify the quality of the water meets these guidelines.

After testing your water for potability, you must also test your water at least once a month for the presence of E. coli, and you must document how you will do this in your procedures. Your water testing procedures should include your sampling method, sampling frequency, sampling locations, storage conditions for samples prior testing, testing parameters, approved testing laboratories, acceptable limits, corrective actions for when result fall below acceptable limits, and who is responsible for each activity.

You may need to collect water samples from all potable water outlets on site. This includes tank outlets, hoses, exposed taps and even handwashing stations. When sampling your water points, consider that all water points are sampled at least once each year. If you have many water points, you may find it most suitable to use a schedule on a rotational basis so that you are varying your sampling points each month.

You must use a NATA accredited laboratory for your monthly E. coli water testing. For an acceptable result, there must be no detectable E. coli in every 100 ml. You may question why your establishment is required to test your town’s main water supply, when you drink it daily without any issue. The end goal of your site water testing procedure is to confirm that your water supply has not been contaminated. Contamination of water can occur at any point, including at the town water supply, during distribution and at your site (e.g. cracks in water pipes, unclean taps and hoses).

You may also be required to conduct additional water testing, upon request by an importing country or if there is a known issue with the water quality in your geographical area.

All water (including ice) used at the establishment must be potable unless the water is used only in circumstances (specified in the arrangement) where there is no risk of the water coming into contact with or contaminating food products.

If your plant is using potable and non-potable water, the water must be supplied in separate lines (including outlets) and be clearly identified to avoid any cross contamination. Ideally, non-potable water outlets should be in separate areas to potable water outlets and be colour coded.

Any recirculated water at the establishment must have a separate distribution system that is clearly identified for recirculated water.

If non-potable or recycled water is used in your premises, it must undergo a risk assessment and be included in your food safety plan. Risk assessment should indicate the nature of the water and in what circumstances it can be used.

In documenting and reviewing your water sampling and testing procedure, you should consider the following:

  • Do you ensure your water sampling locations are designed to check all potential risk points? For example, does the reticulation system prevent the potential of backflow of used or contaminated water?
  • Is there a risk to your product from any non-potable water on site?
  • Do you have a schematic diagram or map to show location of water points and outlets? Consider a scheduled system with rotating water sampling points to ensure you are checking all points in your facility and not sampling from the same location each time.
  • Is it clear who is responsible for aseptic sampling, the date/time and where?
  • Are the details recorded accurate, in the sample and laboratory report?
  • Are responsible personnel trained on proper procedures and do you have training records to confirm this?
  • Are there other situations that could trigger contamination of water, such as floods, earthquakes or sewerage issues? How would you respond to this?
  • Are testing and verification results for water readily available?
  • Do you have E. coli results for your potable water? Are the results from a NATA accredited laboratory? Is the testing method used clearly stated and is it consistent with the Australian Standard testing method?
  • Is it clear from the NATA analysis reports where the samples were taken and when, and whether the results passed or failed?
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Self Assessment

How much do you know about Water sampling and testing?

Take this short assessment to find out.

Question 1

Mateo is the new lab assistant at a dairy facility and he is responsible for sampling and testing the site water supply every week.  He is a qualified microbiologist.  

The approved arrangement  states monthly water tests must be conducted by a NATA accredited laboratory. Mateo is familiar with the microbiology testing method and has decided to conduct the water testing at the on site laboratory.

Is Mateo suitable to conduct the water testing on site instead of using a NATA accredited laboratory?

Click all that apply.

Question 2

Davina works at a dairy facility as an operator.  Davina is responsible for taking water samples at designated location points throughout the site based on the company’s water testing plan. As an emergency has come up at home she will not have time to take the last few samples on her sampling schedule. The schedule was designed to ensure all samples are taken on a rotational basis each week.

What should Davina do to ensure that she meets the requirements of the Approved Arrangement?

Choose the correct response.

Question 3

Ping has recently joined the dairy site as the new Quality coordinator. The site had recently installed a new water storage tank to allow for greater production volume. Ping is tasked with collecting water samples for the new water supply line and has noted the production line has two water sampling outlets, one is prior to the new storage tank and one after. Ping suspects the water sample should be taken after the storage tank, prior to production use. 

What should Ping do to ensure the water supplied to production is adequately sampled and is potable?

Click all that apply.