FDA updates pre-harvest water rules

By Blake Jackson

The FDA recently issued a final ruling on pre-harvest agricultural water requirements for farms covered by the Produce Safety Rule (PSR).

The PSR sets standards to ensure safe fruits and vegetables for consumption. This focuses on the changes to pre-harvest water, while the requirements for post-harvest water remain unchanged.

Previously, growers had to test their water source and build a water-quality profile. Now, the focus is on a systems-based assessment to identify and manage risks related to pre-harvest water.

This assessment requires documentation that identifies potential contamination sources and mitigation measures to minimize risks.

Risk Evaluation:

• Water Source: Surface water generally carries a higher risk than groundwater or municipal water.
• Irrigation System: Check for leaks and ensure proper storage of water to prevent contamination.
• Potential Contamination Sources: Look for nearby animals, neighboring farms, or storage of organic materials that could contaminate your water source or irrigation system.

Water Management Practices:

• Irrigation Method: Localized irrigation (drip) poses a lower risk than overhead irrigation.
• Application Interval: Sunlight and drying can kill some microbes over time. However, this can only be used as a mitigation strategy if the initial evaluation indicates safe water.
• Crop Characteristics: Crops like strawberries with a low-growing habit or fruits prone to cracks and bruises have a higher risk of contamination.

Environmental Conditions:

Identify any other factors that might impact water safety, such as flooding, wildlife activity, or public access to your water source.

Corrective and Mitigation Strategies:

Based on the risk evaluation, determine if corrective actions are needed to reduce contamination risks.

Every farm is unique, so consulting your local extension agent for developing mitigation strategies is recommended.

Recordkeeping and Maintenance:

Regularly inspect and maintain your water system and update your pre-harvest water assessment annually or whenever water management practices change.

Exemptions:

Farms can be exempt from the assessment if they can demonstrate their pre-harvest water meets the same standards as harvest and post-harvest water (no detectable E. coli).

This can be achieved by using untreated surface water, a water treatment system with documented effectiveness, or public water supply with verification of its quality.

The deadlines for complying with the pre-harvest water rule vary based on farm size. Farms with the highest sales volume must comply by April 7, 2025, while very small farms have until April 5, 2027.

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