Water is the lifeblood of any farm. It grows our crops, washes our produce, and keeps our operations running. But it’s also a primary vehicle for contamination. In fact, many global foodborne illness outbreaks have been traced back to the use of contaminated water.
For this reason, the Freshcare Food Safety & Quality Standard has very specific and strict rules for how you manage and test your water. Getting this right is non-negotiable for passing your audit and producing safe food.
At AgriQulture Consulting, we know that navigating these water rules can be confusing. This guide breaks down Freshcare F6 into a clear, step-by-step process.
Step 1: Know and Manage Your Water Sources (F6.1)
You can’t manage what you haven’t identified. The first step in your water management plan is to map out your entire system.
What you need to do:
- Identify all water sources you use both before and after harvest. This includes dams, bores, rivers, tanks, and town water supply.
- Record these sources using a document like Freshcare’s Form – F6 Water source record.
- Show these sources, along with extraction points and delivery infrastructure (pipes), on your property map.
- Monitor and manage your sources to minimise potential contamination from livestock, wildlife, runoff, or other human activities.
Why it matters:
This process forces you to assess the unique risks to each water source. A deep, covered bore has a very different risk profile from an open dam that is accessible to livestock and wildlife. Identifying these risks is the first step to controlling them.
AgriQulture Tip:
Physically inspect your water sources regularly. Look for signs of contamination like algal blooms, dead animals, or evidence of runoff from nearby manure stockpiles or septic systems. Fencing off dams or waterways to restrict livestock access is a key control measure.
Step 2: Pre-Harvest Water and the “48-Hour Rule” (F6.2)
This section deals with water used before harvest, such as for irrigation, fertigation, or crop sprays. The risk level is determined by when it’s applied.
What you need to do:
Your pre-harvest water risk assessment (F1.4) will guide your actions. The critical question is whether water directly contacts the harvestable part of a crop that may be eaten uncooked within 48 hours of harvest.
- If YES, the risk is considered high. You must be able to prove your water quality meets the Freshcare standard.
- If NO (i.e., your last irrigation is more than 48 hours before harvest starts), the risk is low, and no water quality limit applies for this use.
The Limit: < 100 cfu/100mL of E. coli
For that high-risk, 48-hour window, you must have a test result showing that your water has less than 100 colony-forming units (cfu) of E. coli per 100mL.
Why it matters:
The 48-hour period is a critical timeframe. Research has shown that populations of human pathogens on plant surfaces decline rapidly after contamination. Water applied more than 48 hours before harvest therefore poses minimal risk. It is that final window before picking where the risk is highest.
Auditor’s Insight:
An auditor will cross-reference your irrigation and spray application records with your harvest records to verify compliance with this rule. Make sure your dates and times are accurate.
Step 3: Post-Harvest & Hand Washing: The Highest Standard (F6.3 & F6.4)
This is the most stringent category. It applies to any water that touches produce after it has been picked (e.g., in dump tanks, flumes, washing, hydro-cooling) and any water used for handwashing or cleaning food-contact surfaces.
The Limit: < 1 cfu/100mL of E. coli
All water in this category must be of potable (drinking water) quality. This means your test results must show less than 1 cfu of E. coli per 100mL (effectively, a non-detect).
Why it matters:
Post-harvest water can introduce and spread pathogens across an entire batch of produce. Furthermore, a phenomenon can occur where warm produce dipped into colder water contracts, potentially drawing contaminated water inside the product where it can’t be washed off. This is why the standard is so strict.
The Handwashing Exception:
If you cannot prove your handwashing water meets the < 1 cfu/100mL limit, Freshcare allows an alternative control: you must provide and instruct workers to use an alcohol-based hand sanitiser after they have washed their hands with soap and water.
Recirculated Water:
If you recirculate water in a dump tank or flume, it must be treated with a sanitiser and/or changed at an appropriate frequency to maintain that < 1 cfu/100mL quality. You must keep records of your treatment and monitoring (e.g., chlorine checks).
Frequently Asked Questions (FAQ)
For stable sources like a deep bore, you may only need to test annually once you have at least four consecutive clean tests. For variable sources like dams, rivers, or channels, you should test frequently during the period of use. You should also consider testing after events that could affect quality, such as heavy rainfall.
Always take the sample from the point of use, not the source. For irrigation, this might be a sprinkler head or dripper. For the packhouse, this would be the tap or hose nozzle. This tests the quality of the water after it has travelled through your entire infrastructure.
CFU (colony-forming units) and MPN (most probable number) are two different laboratory methods for estimating bacteria levels. While the science differs, for the purpose of your Freshcare compliance, the limits are treated as equivalent (e.g., a limit of 1 CFU is the same as 1 MPN).
You must not use water contaminated by toxic algae if it will directly contact the harvestable part of your crop, or for any post-harvest purpose. You will need to use an alternative, clean water source.
Water is a critical control point in any food safety system. Unsure about your testing schedule or how to interpret your results? AgriQulture Consulting can help you develop a simple, compliant water management plan. Contact us for an on-farm consultation.


