The second FDA Proposed Produce Food Safety Rule Q & A conference call, coordinated by the Produce Safety Alliance, was held yesterday. This conference call focused on agricultural water use in the proposed rule. To comment on these proposed rules go to Docket Folder Summary: Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption. Comments are due by May 16, 2013
Here are the highlights of yesterday’s conference call:
1. What is defined as agricultural water?
Agricultural water is defined as water that is intended to, or is likely to, contact covered produce or food-contact surfaces, including water used in growing activities (including irrigation water applied using direct water application methods -overhead, water used for preparing crop sprays and water used for growing sprouts) and in harvesting, packing and holding activities. Essentially if water used on the farm is going to or has the potential to contact a produce that is not exempt from this rule that water is subject to the requirements of this rule.
Water that does not have the potential or intent to come in contact with produce covered by this rule is considered indirect water and is not subject to this rule. Drip irrigation would be considered indirect.
2. How often should agricultural water be tested?
Municipal water does not need to be tested. A copy of the municipal water analysis is sufficient. Well water should be tested at the beginning of the production season and every three months when in production. For surface water, there are two options. Water that is pumped from a well into a holding pond would need to be tested once a month and water from streams, lakes, rivers, ponds, etc. would need testing at least every seven days.
3. What do you do if your generic E. coli water test results come back higher than they should?
This question was asked in regards to the Food Drug and Cosmetic Act rule which states that if a food product is contaminated with a human pathogen that is then deemed an adulterated crop. A crop that has been irrigated with water that is later shown to be above the accepted generic E. coli standard is not considered adulterated since generic E. coli is not a true indication of the presence of pathogenic E. coli. In this case the grower would need to stop using that water source, identify the problem and fix it or treat the water before he/she could begin using that water again.
4. When is it OK to use water with generic E. coli levels above the stated thresholds?
Many growers use water that has known levels of generic E. coli, including water from ponds, streams, snow melt, and other types of surface water. Drip irrigation and sub-surface methods of irrigation are acceptable forms of irrigation for surface water source water. The question was posed regarding root vegetables, was sub-surface irrigation considered as not having contact with the produce? The FDA seeks comments from growers using these types of irrigation methods with root crops so that it can better understand production practices and therefore contamination risks.
Generic E. coli thresholds for agricultural water according to the FDA proposed rule:
Average 5 sample mean of 126 CVU per 100 ml water and no more than 1 sample above 235 CFU per 100 ml water.
4. Is frost protection water included in this rule?
If the frost protection water is coming in contact with a harvestable product than yes, it is covered by this rule.
The next Q&A conference call on April 22nd at 11 AM will cover soil amendments. Anyone can participate by dialing toll-free 866-906-9888 and entering the passcode: 8140591. Each of these calls are recorded and are being made public online: Cornell University Produce Safety Alliance.
