# County Water Is Not Automatically Factory Water: Why Food Plants Must Test at the Tap, Not Trust the Source

*By Isaac Muthui, CEO, Tamalaki Business Network Ltd*

Ask a food factory where its water comes from, and you usually get a confident answer: "County mains." "Our own borehole." "We buy from a bowser when supply is low."

Ask the next question, "When did you last test the water at the tap your line actually uses?", and the confidence often fades.

Water is in almost everything a food plant does. It goes into juice, yoghurt, bread dough and syrups. It becomes ice. It washes fruit, vegetables and grain. It cleans tanks, pipes, fillers and floors. It runs through the handwash basins at the entrance to production. Yet it is often the one input that arrives without a delivery note, a certificate or a batch number, and nobody signs for it.

This article is for production leads, QA officers, engineers and owners of small and mid-sized food and agro factories in Kenya and East Africa: dairies, juice and beverage makers, bakeries, millers, edible-oil processors, meat and fish handlers, fresh-produce packers and snack makers. It gives you an eight-step **water quality checklist for food factories** that you can run with your own team and an accredited laboratory. It is operations guidance, not legal advice; confirm the specifics with your county public health office, KEBS and your laboratory.

## What the rules and standards actually say

Kenya's baseline sits in the [Food, Drugs and Chemical Substances (Food Hygiene) Regulations, 1978](https://faolex.fao.org/docs/pdf/ken106527.pdf), made under the Food, Drugs and Chemical Substances Act (Cap. 254). On water, the points that matter most are:

- **A potable, adequate supply.** Regulation 11(1)(b) says no premises may be used as a food plant unless the water supply comes from an adequate source, is sufficient for the intended operations and is potable. Regulation 11(1)(c) requires running water at a suitable temperature wherever food is processed and equipment, utensils and containers are cleaned.
- **Plumbing that cannot contaminate.** Regulation 11(1)(e) requires plumbing of adequate size and design that carries enough water to every area that needs it and is no source of contamination to ingredients, food products and water supplies.
- **Potable water for washing food and making ice.** Part A of the Second Schedule, which applies through regulation 14(c), says water used for cleaning food products must be of potable quality, and that ice used with food products must be made from potable water and protected from contamination. It also expects testing procedures to be used where necessary to identify sanitation failures or food contamination, and contaminated food to be rejected or adequately treated.

The Ministry of Health's [Public Health Checklist for Food Hygiene Licensing (2023)](https://www.health.go.ke/sites/default/files/2023-05/Checklist%20for%20Food%20Hygiene%20Licensing%20April%202023.pdf) has a line on exactly this. Under "Water quality control" (item 12.2), it asks food businesses to put in place measures to monitor the quality of both raw and treated water. If you are preparing for a hygiene licensing inspection, that is one of the lines you will be checked against.

The Kenyan specification for potable water is [KS EAS 12:2018, Potable water – Specification](https://webstore.kebs.org/index.php?product_id=14909&route=product%2Fproduct), sold by KEBS. It specifies requirements, sampling and test methods for potable water intended for direct human consumption, domestic and industrial use. Ask your laboratory to report results against it.

Internationally, the Codex [General Principles of Food Hygiene (CXC 1-1969)](https://doi.org/10.4060/cc6125en) covers water in section 13.3. Water, and ice and steam made from it, should be fit for its intended purpose based on a risk-based approach and should not contaminate food. Water and ice should be stored and handled so they do not become contaminated. Water that is not fit for food contact, such as some fire-control water or steam that never touches food, should run in a separate system that does not connect with, or allow reflux into, the water that does. Section 9.2.1 adds that plumbing should prevent backflow and cross-connections, and section 13.4 says records should be kept for longer than the product's shelf life, or as the competent authority decides.

Codex goes further in the [Guidelines for the Safe Use and Reuse of Water in Food Production and Processing (CXG 100-2023)](https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXG%2B100-2023%252FCXG_100e.pdf). Water should be fit for each specific purpose, and deciding whether it is fit for purpose should rest on a hazard analysis of the source, how the food will be eaten and the treatments applied.

For the numbers, the WHO [Guidelines for Drinking-water Quality, fourth edition incorporating the first and second addenda (2022)](https://www.who.int/publications/i/item/9789240045064) is the international reference for the numbers:

- **E. coli** (or thermotolerant coliform bacteria) must not be detectable in any 100 ml sample of water directly intended for drinking, and immediate investigative action must be taken if E. coli is detected (Table 7.10).
- **Chlorine:** for effective disinfection there should be a free chlorine residual of at least 0.5 mg/l after at least 30 minutes' contact time at pH below 8.0, and the minimum free chlorine residual at the point of delivery should be 0.2 mg/l ([Table 8.17](https://www.ncbi.nlm.nih.gov/books/NBK579467/table/ch8.tab17/)).
- **Tanker water:** where large volumes are delivered by tanker, adding chlorine to give a free residual of at least 0.5 mg/l at the point of delivery is desirable, and tankers should be used only for water or be thoroughly cleaned before use (section 6.3).
- **Food processing:** WHO notes that some food processes have special water quality requirements that drinking-water quality does not necessarily guarantee, and that variations that may be tolerated occasionally in a drinking-water supply may be unacceptable in food processing, with possible financial impact through product recalls (section 6.16).

Put together, a simple floor rule follows: **know every source and every use, protect the water from the source to the tap, check it where you use it, and keep the records that prove it.**

## Why "we are on county water" is not a control

Mains water, borehole water and bought water all go wrong in the same three places:

1. **Between the source and your tap.** Whatever quality the water has when it reaches your gate, your own storage tanks, pipes, hoses and filters can change it. WHO's guidelines specifically mention contamination of drinking water inside buildings from deficient roof storage tanks and cross-connections with wastewater pipes.
2. **When the source changes.** In the dry season many plants top up with tanker water or switch to a borehole. A different source means a different risk, and WHO says bulk water should be treated as another source in the receiving system's plan.
3. **When nobody is looking.** A chlorine dosing pump runs dry. A tank lid is left off after maintenance. A cleaning hose is left lying on the floor. None of this shows up in a lab report taken six months ago.

**Illustration (not real customer data):** a juice processor uses county water, stored in a roof tank, for blending, and a borehole for floor washing. During a dry spell, the store manager orders two tanker loads straight into the same roof tank. Nobody records the tanker, checks the chlorine, or looks at the tank afterwards. If a customer complaint arrives two weeks later, the plant has no way of telling which batches were made with which water. One line in an intake log and one chlorine reading would have answered the question.

## The 8-step water quality checklist

### 1\. Map every source and every use

- List every source: county mains, borehole, tanker or bowser deliveries, rainwater, and any treatment you run (filters, softeners, chlorination, UV, reverse osmosis).
- List every use, and mark what each one needs. Water that goes **into** the product, becomes **ice**, or **washes food** must be potable under the Second Schedule. Regulation 11(1)(b) expects the plant's supply as a whole to be potable, so handwash water and water for cleaning food-contact surfaces should be potable too. Water for fire control, boilers whose steam never touches food, or some cooling uses may be fit for purpose at a different quality, as Codex allows, but only if you have assessed it.
- Draw it on a simple plan: source, tanks, treatment, main pipe runs and the points of use.

### 2\. Number your sampling points

- Mark and number the points where you will check the water: the inlet, after each treatment step, each storage tank outlet, and the taps that feed the product, CIP and handwash.
- Include the worst-case points, such as the tap furthest from the tank, a little-used line or the end of a long hose.
- Without numbers, "the water was fine" means nothing. With them, it becomes "sample point 7, the blending-room tap, free chlorine 0.1 mg/l on Tuesday".

### 3\. Protect and clean storage tanks

- Keep every tank covered, with a tight, lockable lid and screened vents and overflows, so dust, birds, insects and rodents cannot get in. This ties back to our [pest control checklist](https://factoraerp.com/en/blog/pest-control-checklist-food-factories-kenya).
- Put tank cleaning and inspection on a fixed schedule in your [preventive maintenance](https://factoraerp.com/en/blog/preventive-maintenance-basics-food-agro-factories-kenya) plan, and record who cleaned it, when, how, and when it was refilled and checked.
- Keep the area around tanks drained and clean, and restrict access to authorised staff.

### 4\. Keep non-potable water separate and stop backflow

- Label pipes so anyone can tell potable from non-potable lines. WHO's guidance on dual piped supplies (section 6.7) calls for unambiguous labelling and installation by qualified plumbers, and Codex asks for a separate system for water that is not fit for food contact, with no connection or reflux into the food-contact system.
- Fit and maintain backflow protection, such as non-return valves, where potable water connects to equipment, chemical dosing or hoses. Codex section 9.2.1 asks for steps to prevent backflow and cross-connections.
- Check hoses: hung up off the floor, with the ends protected, drained after use. A hose lying in a floor drain is a cross-connection waiting to happen.
- Treat any plumbing change as a risk. Approve it and record it before it happens, not after.

### 5\. Check every water delivery like any other raw material

If you buy water by tanker, treat the tanker like a delivery truck at your gate. Add a water line to your [supplier intake checklist](https://factoraerp.com/en/blog/supplier-intake-checklist-food-manufacturers-kenya):

- Record the supplier, the tanker registration, the declared source, the date, the volume and the tank it went into.
- Look at the tanker: is it dedicated to water, clean, and are the hose and coupling protected? WHO says tankers should be used only for water or thoroughly cleaned before use.
- Measure free chlorine and look at the water (colour, smell, visible particles) before it goes into your tank. Reject or segregate a load that does not meet your acceptance rule, and record why.

### 6\. Run simple daily checks where the water is used

- At the start of each shift, at the numbered points that feed the product, measure free chlorine and pH with a test kit, and note the appearance and smell. If you dose chlorine yourself, set your target range with your water treatment provider. WHO's reference points are at least 0.5 mg/l free chlorine after 30 minutes' contact at pH below 8.0, and at least 0.2 mg/l at the point of delivery.
- If you run filters, softeners, UV or reverse osmosis, record the checks that tell you they are working: pressure, filter changes, lamp hours, as your supplier specifies.
- Record every reading: point number, date, time, result, who checked. A reading that is not written down did not happen.

### 7\. Verify with an accredited laboratory

- Send samples from your numbered points to an accredited laboratory on a fixed schedule, and ask it to report against KS EAS 12:2018. Agree the frequency and parameters with the lab and your public health officer, based on your source and how you use the water.
- Test the raw source and the treated water. That is exactly what the Ministry of Health checklist asks for in item 12.2.
- Retest after anything that could change the water: a new source, a tanker top-up, a tank cleaning, a plumbing repair, or a heavy rain event on a borehole.
- File the certificates with the sample point, the date and the batch window they cover.

### 8\. Act on failures, protect product and keep the file

When a check fails, for example chlorine below your minimum, E. coli detected, or an odd colour or smell:

- Stop using the affected point for product, ice or food washing until the cause is found and fixed. WHO says immediate investigative action must be taken if E. coli is detected.
- Find the cause: tank, treatment, delivery, cross-connection or sampling error. Fix it and retest before you go back to normal.
- Identify the batches made with that water since the last good result, and place them on a [QA hold](https://factoraerp.com/en/blog/qa-hold-checklist-before-batch-leaves-warehouse-kenya) until they are assessed. The Second Schedule expects contaminated food to be rejected or adequately treated.
- Clean and verify the affected lines before restart, following your [line clearance checklist](https://factoraerp.com/en/blog/line-clearance-checklist-food-factories-kenya).
- Keep the source map, sampling-point plan, daily logs, delivery records, tank cleaning records, lab certificates and corrective actions together, for longer than the shelf life of your products (Codex section 13.4). If a complaint arrives, this file plus your batch records is what lets you answer it, which is what a [mock recall](https://factoraerp.com/en/blog/how-to-run-a-mock-recall-food-traceability-kenya) tests.

## Habits that make water control stick

- **Every source is a supplier.** Mains, borehole or tanker, each one gets recorded.
- **Every sampling point has a number.** A result always has a location.
- **Check where you use it.** The tap that feeds the blender matters more than the meter at the gate.
- **A change means a retest.** New source, new tank, new pipe: test before you trust.
- **A failed result opens a hold.** Water problems are batch problems.

## Where an ERP helps

A test kit, a clipboard and a reliable laboratory can run this checklist on one site with one source. It gets harder when you have several sources, seasonal tanker deliveries, many lines and a lot of batches to trace.

FactoraERP tracks production batches and lots, stock status including QA holds, non-conformance records and stock adjustments with reason codes. That means a failed water check can be logged as a non-conformance with an owner, linked to the batches produced in that window, those lots can be put on hold, and any product written off gets a reason code instead of disappearing. See [factoraerp.com](https://factoraerp.com).

## Free download: eTIMS readiness checklist for factories

Hygiene records, stock records and invoices increasingly have to tell the same story for Kenyan manufacturers. If you want a free **eTIMS readiness checklist for factories**, sign up for the FactoraERP Insights newsletter at <https://isaacmuthui.substack.com>. You will get practical operations notes for food and agro manufacturers. No spam; unsubscribe anytime.

## FAQ

**What should a water quality checklist for a food factory include?**\
A map of every water source and use, numbered sampling points, covered and regularly cleaned storage tanks, separation of non-potable water and backflow protection, checks on tanker deliveries, daily free chlorine and pH checks at points of use, periodic accredited laboratory testing, and a procedure for failures that includes holding affected batches and keeping records.

**Is county mains water automatically safe to use in food production?**\
Not automatically at the point of use. Even good water at the gate can be contaminated by storage tanks, pipes, hoses and cross-connections inside your plant. WHO's guidelines mention contamination from deficient roof storage tanks and cross-connections with wastewater pipes. Check the water at the taps your lines use.

**What does Kenyan law require on water in food plants?**\
The Food, Drugs and Chemical Substances (Food Hygiene) Regulations, 1978 require a potable water supply from an adequate source (regulation 11(1)(b)), plumbing that is no source of contamination (regulation 11(1)(e)), and potable water for washing food and making ice (Second Schedule, Part A). The Ministry of Health's licensing checklist asks for monitoring of both raw and treated water. Confirm specifics with your county public health office.

**Which standard should our laboratory test against?**\
KS EAS 12:2018, Potable water – Specification, available from KEBS, covers potable water for direct human consumption, domestic and industrial use. WHO's Guidelines for Drinking-water Quality is the international reference. Agree the parameters and frequency with an accredited laboratory.

**How much chlorine should be in our water?**\
WHO's guidelines say effective disinfection needs a free chlorine residual of at least 0.5 mg/l after at least 30 minutes' contact at pH below 8.0, with at least 0.2 mg/l at the point of delivery. The right range for your plant depends on your source, treatment and products, so set it with your water treatment provider.

**Can we use borehole or tanker water?**\
Yes, if it is fit for its intended use. Codex CXC 1-1969 and CXG 100-2023 take a risk-based, fit-for-purpose approach, but water that goes into the product, becomes ice or washes food must be potable under the Kenyan regulations. Test the source, treat it as needed, and record every delivery.

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*Isaac Muthui, CEO, Tamalaki Business Network Ltd*

*Originally published at* [*factoraerp.com*](https://factoraerp.com/en/blog/water-quality-checklist-food-factories-kenya)*.*