Audit Ready: Heads Up on Handwashing Stations, Well Water Sampling, & Traceability

Handwashing Stations

Auditors have noted that on handwashing stations some have a label which says “Not potable water.” If a grower is doing the USDA GAP or Harmonized audits, the water in handwashing stations must meet the “Microbial standard for drinking water.” If a label is on the wash station marked not potable, the grower is not in compliance. Check G-9 in the GAP or 2.2.5 in the Field Operations and Harvesting Harmonized Food Safety Standard for more details.

From Grower Self Audit for USDA GAP Audit General Questions G-1 to G-15:
G-9. All toilet/restroom facilities are clean and properly supplied with single use towels, toilet paper, and hand soap or anti-bacterial soap and potable water for hand washing.

Well Water: Number of Water Samples Required

There has been some confusion as to the number of water samples needed for Harmonized or GAP audits. Each well must be tested each year for generic E. coli.

Surface water such as streams, ponds and rivers must be tested three times a year (at the beginning of irrigation, mid-season and approximately two weeks prior to harvest).

– If the water source is for irrigation only, some generic E. coli is acceptable (126 colony forming units (CFU) or most probable number (MPN)/100 ml of water).
– However, if the well is used in the packing operation the acceptable E. coli level is 0.

 
Some testing companies have told growers they need five tests for an audit. That is not true for most growers. The only time a grower may need to meet the higher standard is if their buyer requires it.

Product Traceability

There are differences between audits as to how product must be identified for traceability.

– With the GAP audit each container or box must be labeled with at least the name and address of the shipper plus a code with the harvest date and field from which the product was harvested.
– With the Harmonized audit, each box does not need to have the harvest date and field on the box, but the same information must be on a pallet tag.

 
If the grower is packing under someone else’s name, the grower’s name, address, harvest date and field number must still be on the pallet tag.

Do all box, crates, bulk bins need to be labeled?
The final carton whether cardboard, wood or plastic must have the name and address of the shipper. In some instances the grower may be using someone else’s container i.e. the buyer may want their container used. That is acceptable if the buyer’s name and address is on the container. However, if a generic container is used the grower must label each box with their name and address!