Changes to affect microbial risk assessment of preharvest water
FDA has been working with stakeholders to address the challenges and complexity surrounding the current agricultural water provision of the Produce Safety Rule and has made proposed amendments to the Produce Safety Rule Subpart E provision.
The following are key highlights that could affect your farm operation, specifically pre-harvest agricultural water requirements for covered produce (excluding sprouts):
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The proposal would replace the microbial criteria and testing requirements for pre-harvest agricultural water for covered produce (other than sprouts) with provisions for systems-based agricultural water assessments. Prior to this proposed revision, farms subject to the Produce Safety Rule were required to test the farm water source based on specific criteria: test ground water four times over one year and surface water 20 times in two to four years to establish a microbial water quality profile and test less frequently in subsequent years as shown in this factsheet. FDA is proposing to remove this testing requirement and require farms to manage risks and test water based on the intended use of the water for safe or adequate sanitary quality.
- The annual systems-based agricultural water assessment would include an evaluation of the water system, agricultural water use practices, crop characteristics, environmental conditions, potential impacts on source water by activities conducted on adjacent and nearby land, and other relevant factors, such as the results of optional testing.
- In light of findings from several recent produce outbreak investigations, the proposal also includes expedited mitigation measures that would be required for specific types of hazards related to certain activities associated with adjacent and nearby lands.
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The proposed rule does not include a delay in the January 22, 2022 compliance dates for large farms (>$500,000 in average annual produce sales for the previous three years), but a subsequent rule is currently under review to further the compliance delay. Large farms may need to demonstrate establishing a MWQP prior to this year's Produce Safety Rule inspection. See this set of resources to be prepared. If the proposed rule is adopted, our team will send updated notifications of changes.
If finalized, this provision would provide a more comprehensive strategy for addressing microbial contamination of agriculture water systems. There is a 120-day comment period with 2 virtual public meetings on the amended rule that are not yet announced. Stay tuned for more information from the Produce Safety Alliance about the proposed rule and opportunities to learn more.
Please reach out to Dr. Amanda Philyaw Perez, Extension Food Safety Specialist, at aperez@uada.edu or Angela Gardner, Program Associate, at agardner@uada.edu with any questions.
Additional reading on proposed changes to agricultural water requirements from the FDA
