Water testing is a major component of FSMA. The Food and Drug Administration (FDA) requires that growers begin sampling agricultural water to create a microbial water quality profile when they need to start complying with FSMA. No grower needs to start sampling until January, 2018 (growers over $500,000), small growers 2019 (growers between $250,000 and $500,000) and very small growers 2020 ($25,000 to $250,000). All growers have 2 to 4 years to complete sampling. How many samples are needed is not clear at this point. FDA is revisiting the water requirements outlined in the Produce Safety Rule (PSR). At present, the Rule states that for surface water 20 samples collected over 2 to 4 years would be needed then 5 samples every year following. For well water it would be 4 samples then 1 sample every year after. They are working to simplify the standards. We do not know when the new standard will be published.
What is needed from the water test? Water should be tested for generic E. coli. There is no need to test for any other organism. There are different methods that laboratories use to assess generic E. coli, but the one FDA has set as the standard is EPA Method 1603. This method is available in some laboratories in New Jersey and if possible ask the lab to use it. The problem with the method is some states do not have any labs that can use this method.
When thinking about water testing, growers should understand the definition of “Agricultural Water” under the PSR. Agricultural Water – “Water used in covered activities on covered produce where water 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, water used for preparing crop sprays and water used for growing sprouts) and in harvesting, packing and holding activities (including water used for washing or cooling harvested produce and water used for preventing dehydration of covered produce).” In other words, any water that touches the final harvestable produce including spray water is agricultural water. If the grower uses drip and it is working properly, it is not “Agricultural Water”. However, if that same water source is used for spraying or over irrigating it is “Agricultural Water.”
So what should a grower do now? Any grower who has been sampling for a third party audit should continue to sample using the same method and frequency. Any grower who has not been sampling may want to begin sampling just to get an idea of their water quality.
