Bridging the GAPs: Approaches to Treating Water On Farms

As mentioned, maintaining records is required when implementing corrective actions. The following information should be documented:

Product identification

Description of problem

Corrective action

Fate of product

Person responsible for corrective action

Determination of root cause

Actions to prevent future occurrence

Results of evaluations and testing

• Follow-up to ensure corrective actions were followed

Corrective action records should reflect the disposition of affected produce. Within these records, reasoning behind decisions should also be addressed and include all fields affected by the deviation. Depending on the actions taken, there should be documentation for alternative corrective measures used, outlining the details of the measures taken. If the produce is diverted to commercial processing, a letter of assurance must be obtained by the processors stating that a validated kill step will be applied to the produce. If the produce will be destroyed, a date and signature of the individual responsible must be included in the document.

Val idation and Ver if ication

Validation and verification are key components of an effective irrigation water treatment system. Quite frankly, without addressing these components, growers may be wasting resources and time. These terms are often mistakenly used interchangeably in the food industry; however, they each have distinct definitions and roles in supporting a successful treatment system. Validation is scientific evidence and proof that the treatment system is working and actually reducing the risk of pathogenic contamination. That is, the right technology is being applied. Verification, on the other hand, provides the grower information that the system is working according to his or her plan, as well as meeting federal requirements or third-party standards. Verification is conducted routinely and is an ongoing process that provides evidence that the plan is properly implemented. (Figure 2).

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