Dump Tank Wash Water Control Measures

I recently had a PrimusGFS thrid party audit on fresh market cucumbers. I was marked down on the Module 3-Haccp section due to my risk assessment because I did not make my Dump Tank Wash Water a ccp. I'm looking on advice on how to make that step a ccp when the water is fresh re-ciruclated well water only, there is no chlorinated step in the water.

The only solution I have come up with is that I have water tests of the water, daily sanitation of the dump tank, along with changing the water daily and more if needed.

Can anyone offer any advice on how I can fix this.

Thanks

Primus is going to be really touchy about this one.  They are being sued by just about everyone over the cantaloupe debacle at Jensen Farms in Colorado.  If the water is being re-circulated you need some kind of antibacterial solution in there such as chlorine, or peracetic acid just to name a few choices or you are going to get bacterial loading.  Even if it is one pass then  having an antibacterial wash greatly reduces your liability.  If your going to use chlorine then you will also need to adjust the pH of the water as well. 

Depending on your volume you can buy probes that will monitor the chemical level so that your manual checks are less frequent.  However you still need to manually validate the system.  You can check the solution manually and the frequency will depend on several factors, including temperature and microbial load just to name a few.  Sounds like you are on the right track. 

I'm not in the produce business.  What is your system doing just washing down the vegetable or is it supposed to "disinfect the outside"?

Sorry I don't know much about your process