Water testing requirements for milk and milk product manufacturing establishments

Minimum water quality standards

Water used in registered establishments may come from a number of sources:

  • town water provided through a commercial water supplier
  • dams and rivers
  • bore water
  • rain water
  • water reclaimed from milk and milk products.

The Export Control (Milk and Milk Products) Orders 2005 require that water used for processing must be potable.

Water potability standards are described in the Australian Drinking Water Guidelines prepared by the National Health and Medical Research Council.

Activities must be undertaken to verify the quality of the water supply, with evidence available to demonstrate the water used complies with the Australian Drinking Water Guidelines. This evidence will be either:

  • test results of the water to demonstrate potability (required for non-town water supplies annually)
  • test results provided by the local water supplier annually.

Where non-potable water is used, procedures must document where that water is used. If water comes into contact with food or food contact surfaces you must verify it will not contaminate the food for export.

Microbiological testing of potable water

Water testing must be conducted at least monthly at a National Association of Testing Authorities, Australia (NATA) accredited laboratory to verify there is no E. coli present in the water supply used throughout the establishment.

The NATA analysis certificate must clearly identify:

  • the laboratory is accredited with NATA to test water and its accredited number
  • the test method used to analyse the water (must be linked to the Australian Standard test method)
  • the manufacturer and the establishment number
  • the point where the sample was taken
  • pass or fail against each specific test.

There may be other situations that trigger additional testing of water, for example:

  • when work has been done on sewage or water piping in your establishment
  • when there has been flooding or heavy rains which may cause back siphonage of reticulation systems or sewage systems
  • when there is obvious issues with the water e.g. discolouration, particles of matter or has an offensive odour or oily film
  • where an importing country requires specific testing.

Documenting your testing regime

The approved arrangement (AA) must document the testing regime required to meet general export requirements including:

  • the source of water used in the establishment
  • the testing parameters required, relevant to the water source (chemical, physical and microbiological)
  • evidence of annual test results from the local water authority (if applicable)
  • a map of the water points
  • the location points of the water to be tested
  • rotation of sampling points
  • who will conduct the testing and what training they have to support the testing
  • the frequency of testing
  • triggers for corrective action
  • corrective actions to be taken when limits are exceeded/ in the event of a failure
  • where the testing is conducted e.g. the NATA accredited laboratory (in-house or external)
  • what test methods are being used to conduct the specific tests (must be linked to the Australian Standard test method)
  • evidence of the monthly test results (NATA analysis certificate).

Ongoing compliance must be covered through your internal audit and verification program.