Water for use in the preparation of food
Requirements for the Safe Food for Canadians Regulations
Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.
What is potable water?
Potable water is water that meets the standards set out in Health Canada's document Guidelines for Canadians Drinking Water Quality – Summary Table.
Establishments use water in several different ways and for many different reasons. Water is commonly used:
- as an ingredient
- for steam or ice
- as a substance to push, flush or flume food
- to clean food before and during preparation
- for cleaning and sanitizing the establishment and equipment
- as part of the employee hygiene activities
- for fire protection and sprinkler systems
Operators should have, in their establishments, a supply of water that is safe, appropriate for the intended use and of a quantity and pressure sufficient for the operational needs. You should consider the state of the water you use for processing, as potable or non-potable, and its suitability for the intended use. The suitability of water is determined by doing a thorough assessment of the hazards it presents and the risk of contamination to a food.
In Canada, provincial, territorial and municipal governments are generally responsible for ensuring water supplies are safe. The federal government has a number of responsibilities as well. The Federal-Provincial-Territorial Committee on Drinking Water established the Guidelines for Canadian Drinking Water Quality (GCDWQ). The guidelines provide the rationale for safe water, along with microbiological, radiological and chemical safety parameters. The document From Source to Tap: Guidance on the Multi-Barrier Approach to Safe Drinking Water is another useful resource that provides all operators of a water supply with a risk-based management plan for producing potable water – covering water supply, from source to tap.
The Canadian Food Inspection Agency (CFIA) created this document as guidance to help food businesses comply with the requirements set out in the Safe Food for Canadians Regulations.
You may use other guidance developed by provincial governments, industry associations, international partners or academic bodies as long as they can achieve the outcomes identified in the regulations. Always ensure that the guidance you choose is relevant for your particular business, product or products, and market requirements.
What is included
There is a significant amount of information available on the safety of water: its source, use, sampling and testing. This document summarizes some of that information and outlines recommended practices that can help to prevent the risk of contamination of a food by the water you use in your establishment. The document provides information on:
- The classification of water based on its suitability for use
- The identification of the hazards from water and the risk of contamination to a food
- Water sources
- Ongoing assessment of the water's suitability for use
Refer to the Tell me more! section for additional sources of information that may help you ensure the sources of water you use are safe for the intended purpose.
What is not included
While this document provides information on the suitability of water, it is not exhaustive – the suitability of water and the preventive control measures needed will depend on the size and complexity of the food business and be unique for each business.
This document does not address:
- water treatment systems
- the manufacturing and bottling of prepackaged water
You can find information on
- water in the form of ice in the guidance document Ice used in the production of food
- steam in the guidance document Culinary Steam
- water backflow prevention in the guidance document Preventing Water Backflow
Roles and responsibilities
Food businesses are responsible for complying with the law. They demonstrate compliance by ensuring that the commodities and processes for which they are responsible meet regulatory requirements.
The CFIA verifies the compliance of a food business by conducting activities that include inspection, and surveillance. When non-compliance is identified, the CFIA takes appropriate compliance and enforcement actions.
Water for use in the production of food
Given the many different ways water is used, and the many ways food can be exposed to or come into contact with water, the level of risk and the level of control needed may vary, depending on the scenario.
- The pathogens found in water are usually of faecal origin. The presence of E. coli would indicate faecal contamination and the possible presence of enteric pathogens. Different foods can also become contaminated with a variety of spoilage and pathogenic organisms, such as Listeria monocytogenes, Bacillus cereus or Staphylococcus aureus
- Pathogens in water will not normally increase in number and will often decline. But when water is added to a food, the bacteria in the water will then begin to grow quickly because food provides a better growth medium for the bacteria
- Water that meets drinking water safety standards is considered suitable for consumption. When it enters the food production system it may be used for a process such as canning or cooking to reduce or eliminate a hazard like pathogens. On the other hand certain processes, such as the boil over of volatile chemicals into the culinary steam, can concentrate contaminants in water which can present a risk of contamination to a food
Depending on the safety of the source, water could contain either microbiological or chemical hazards. These hazards are an important consideration for the safety of the food process. Relying on the categorisation of water as either potable or non-potable may not always be sufficient depending on the intended use.
Classification of water based on its suitability for use
You should classify each source of water you use based on the potential hazards it presents and intended use. The following are four categories of water based on the general type of hazard and the water's suitability for its intended purpose.
- chemically and microbiologically suitable for its intended use
- chemically suitable for its intended use but microbiologically not suitable for its intended use
- chemically not suitable for its intended use but microbiologically suitable for its intended use
- chemically and microbiologically not suitable for its intended use
The classification of your water can help you determine whether or not a water treatment or a food process step will mitigate the risk. For example, in the case of water classified as category 2 (above), you should consider whether:
- the microbiological hazards would be mitigated by a process you are applying - such as canning or cooking; or
- a disinfection treatment could be used to make the water microbiologically suitable for use.
Identify the hazards from water and risk of contamination
You should identify all potential hazards from water that could be a risk of contamination to a food regardless of whether or not you have direct control over the hazard or its source. This will help you determine:
- whether a particular source of water is suitable or desirable for the intended food process and product
- the type and level of treatment or other controls measure needed to make the water suitable for the intended use
- not all potential hazards will require the same degree of control
- the control measures needed should be based on the risk of contamination to the finished food
- Identify all the points in the process where water could come into contact with the food. Keep the following in mind:
- the purpose of the water
- the nature of the contact
- the environment where the water is introduced
- the step in the process
- the impact of the exposure
- Identify each water source, for example, municipally treated water or well water.
- Determine the hazards a water treatment applied can present if not maintained properly or the hazards water can present if untreated.
- Review the food manufacturing process to determine if there are any existing steps in the process that will, intentionally or unintentionally, prevent any potential hazards from the water from presenting a risk. The process may increase the risk of contamination, reduce the risk or have no tangible effect.
- Evaluate each hazard that may be introduced from the use of water. This will help you determine the level of exposure and the subsequent risk of contamination of the food. Testing may be needed to assess either a microbiological or chemical hazard.
Ask yourself the following when assessing the safety of water for its intended use:
- Is the water potentially contaminated with chemical and/or biological hazards at a concentration with health significance?
- If no, it is safe
- If yes, it is unsafe
- Will the water potentially contaminated with chemical and/or biological hazards be consumed or come into contact with food?
- If no, it is safe
- If yes, it is unsafe
- Is the water potentially contaminated with chemical and/or biological hazards treated to eliminate potential hazards before it comes in contact with the food?
- If yes, it is safe
- If no, it is unsafe
- Will a subsequent treatment of the food, either in the process or by the consumer, eliminate the hazards from the water potentially contaminated with chemical and/or biological hazards?
- If yes, it is safe
- If no, it is unsafe for use
The hazard analysis will help you determine the need to put in place additional water treatments such as filtration or disinfection systems or use a different water source in order to prevent contamination of a food.
The water you use may come from:
- municipal water supplies
- open sources such as lakes, rivers, sea water, and
- underground sources, which may or may not be under the direct influence of surface water
Groundwater wells are required to meet provincial or municipal requirements in regards to the separation of the water supply from potential sources of pollution (such as private sewage systems or wastewater storage lagoons). This can affect their location, construction and commissioning. If you use a private water source or supply, incorporate a protection and monitoring plan for the water source into your multi-barrier approach to water safety. More information can be found in the From Source to Tap: Guidance on the Multi-Barrier Approach to Safe Drinking Water.
Note: In a multi-barrier approach, the barriers are cumulative and work together to make the water suitable for its intended use. The barriers can be physical (such as a filtration system), or they can be processes or tools that improve the overall management of a treatment water system.
Municipal and public water distribution systems
Water used in an establishment is often sourced from locally or municipally controlled water sources.
You should retain a record of the analysis results for source water from the municipality. Usually, water that has been treated by a municipality is of high quality before entering the distribution system but the microbiological and chemical constituents in the water can vary.
It is important to keep in mind that municipal and public water quality has the potential to deteriorate for many reasons:
- The water is disinfected but not sterilized
- Plumbing materials are not 100 percent inert
- Cross-connections and line breaks to the piping may occur in the distribution system or in the establishment, which can result in contamination with non-potable water
- Precipitation of compounds such as calcium carbonate and iron may occur, which may provide favorable conditions for the growth of the organisms present
Water from a private water source
Private water sources are sources operated independently from a municipal water supply that can be described as surface water, ground water, or ground water under the influence of surface water.
Naturally occurring hazards such as minerals like iron, manganese and calcium can be pre-existing in a water supply and may need to be removed. Hazards may also be seasonal or temporary as a result of flooding or power system failures for example.
Potential sources of contamination for a private water source include:
- freshwater streams and rivers
- outlet sites of sewers, septic fields and municipal/private sewage ponds
- outlet sites of industrial effluent discharge
- wharves and other vessel docking infrastructure
- farms, livestock holding, and animal husbandry activities
- standing pools of water within the immediate vicinity of a well
- significant presence of commercial traffic or industrial activities
- distance from the seashore, if tides, erosion, or storm surges may affect the site
- areas where runoff or rainwater may collect and pool, or drain following significant rainfall
A hazard can often be prevented or eliminated by applying a specific water treatment.
- Undesirable chemical contaminants may be removed by filtration, ion exchange, or flocculation
- Microbial contamination may be treated by membrane filtration and/or chemical disinfection
The design, construction, and operation of treatment systems are detailed in various provincial guidelines and are outlined in the document From Source to Tap: Guidance on the Multi-Barrier Approach to Safe Drinking Water.
Tip: Your local municipal and provincial guidelines and regulations apply to the design, construction, commission, licence, operation and maintenance of all private water sources.
Reclaimed and reused water
Reusing and reclaiming water helps conserve water and is a more efficient use of the available water resources.
You should treat and maintain water that is to be reused in a manner that will not increase the risk of contamination of a food.
- In most instances, water that is reclaimed or recycled needs to be treated to improve its quality and to make it safe and suitable for its intended use. This is particularly important when it's intended use will bring it into contact with a food or it is used to clean surfaces that will come into contact with the food
When using reclaimed water or reusing water, consider the following:
- The safety and suitability of the water for its intended use
- Can it adversely affect or jeopardise the safety of the food through the introduction of chemical, microbiological or physical contaminants?
- Does it meet the microbiological and the chemical specifications for potable water in the GCDWQ or will the contaminants be eliminated by a subsequent food processing step?
- Ongoing monitoring and testing to ensure its safety and quality
- The frequency of monitoring and testing should be based on the source of the water, its prior condition and the intended use
- Applying a water treatment system(s) that is designed to:
- address the types of contaminants the water may have acquired from its previous use
- recondition the water in a manner that renders it appropriate for the intended reuse and will not have a deleterious effect on the food
Ongoing assessment of the water's suitability for use
You should monitor the level of contamination of the source water before treatment on an ongoing basis.
- The effectiveness of a treatment is based on the level of contamination of the water being treated. If the level of contamination is not within the limits that can be effectively treated:
- the treated water may not meet water safety standards
- the treatment may need to be adjusted to take into consideration the higher level of contamination of the source water
Water test results may be available from the municipality however you should still sample and test the incoming source water to ensure its safety. Testing should be done at an accredited laboratory using appropriate testing methodologies.
The water entering the establishment should meet the requirements of the official government body having jurisdiction. The water supply should be analyzed at least once per year to confirm its microbiological safety.
In order to conduct a microbiological assessment of the source water, samples need to be taken before the water receives any treatment, such as before the point of chlorination, filtration or water softening.
Note: It is not acceptable for the person taking the sample to request that the water treatment be temporarily stopped in order to obtain an untreated water sample from a tap, or any other sampling site downstream of the site of establishment's water treatment device. Allowing untreated water to flow through the establishments plumbing system downstream of the water treatment site may result in contamination of the plumbing and the establishment.
If the evaluation of the source water identifies that the incoming water needs to be disinfected or treated:
- develop, document and implement procedures to ensure the safety and suitability of the water for its intended use
- install and operate disinfection, filtration or treatment systems (following the manufactures stated directions) to ensure they continually provide water of a quality that meets the source water specifications
The range of chemical analysis depends on local conditions, such as geological formation, seepage from soil treated with fertilizers, pesticides or local exposure to industrial pollution. To establish the range of tests and when to test, you should consult your provincial environmental authorities.
The guidelines for chemical parameters can be found in Health Canada's Guidelines for Canadian Drinking Water Quality.
- Health Canada recommends testing the source water twice a year
- If the source of the water is from the municipality and the chemical analysis is carried out by the municipality, you may use those results as part of your monitoring program
Food contact water
Although the source water may be acceptable, the safety and quality of food contact water should be subject to ongoing monitoring to ensure its continued safety and acceptability.
Generally, food contact water should be tested, at a minimum, once per month.
- Sampling sites should be representative:
- the water should be taken from the different areas throughout the establishment where it comes in contact with a food but not necessarily at the same points each time
- suitable sites for sampling include a drinking water outlet and points of use in the establishment such as a hose
- over time, the sample sites should cover all applicable areas of the establishment
- Sampling will determine if the water lines and filters are sanitary
You should also visually inspect the water sources, lines, equipment, storage tanks and treatment equipment at a frequency adequate to ensure their safe operation.
Water safety alerts and drinking water advisories
If a municipality's water safety or quality is unacceptable, the local public health unit or other responsible authority may issue boil water advisories or water safety alert/drinking water avoidance advisories.
You should have a measure in place, such as a subscription to an email or phone distribution list, which ensures you get notified when there's a municipal water treatment failure and water advisory. It is your responsibility to ensure that the municipal water supply meets requirements at the point of delivery to the establishment.
Health Canada's Canadian Guidelines for Food Processing During Adverse Water Events provides guidance for appropriate actions to be taken during these events.
Tell me more! Further reading
The following references contain information that helps explain food safety controls, demonstrates how to develop them, and provides examples. The CFIA is not responsible for the content of documents that are created by other government agencies or international sources.
- Cleaning and sanitation program
- Conducting a hazard analysis
- Culinary steam
- Preventing cross-contamination
- Canadian Food Inspection System (CFIS) Code of Hygienic Practice for Commercial Prepackaged and Non-Prepackaged Water, 2003
- Canadian Food Inspection System (CFIS). Appendices of the Code of Hygienic Practice for Commercial Prepackaged and Non-Prepackaged Water, 2003
- Codex Alimentarius Commission, Proposed draft guidelines for the hygienic reuse of processing water in food plants
- Government of Ontario, Procedure for Disinfection of Drinking Water in Ontario, 2005
- Government of Ontario Ministry of the Environment, Ontario, Design Guidelines for Drinking Water Systems, 2008
- Health Canada, Water Quality: Reports and Publications
- Health Canada, What's In Your Well – A Guide to Well Water Treatment and Maintenance
- Health Canada, Guidelines for Canadian Drinking Water Quality
- Health Canada, Canadian Guidelines for Food Processing During Adverse Water Events
- Health Canada, Guidelines for Canadian Drinking Water Quality - Chlorine Guideline Technical Document, 2009
- Health Canada From Source To Tap - The Multi-Barrier Approach To Safe Drinking Water, May 2002
- ILSI Europe Environment and Health Task Force, Considering Water Quality for Use in the Food Industry, 2008
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