Does your farm fall under the FSMA: PSR? Find out at this link: https://rutgers.ca1.qualtrics.com/jfe/form/SV_4IagP1mbPyrp42N.
The requirements for water management only apply to operations that are not exempt or qualified exempt. Check out the link above to determine whether you fall under an exemption category.
Note: If you are third party audited (GA/GHP, Harmonized, Global GA, Primus, etc.) continue to follow the water testing requirements for your audit!
Harvest and Post-Harvest Water (including water used to wash hands, washing produce, ice making, hydrocooling, chemical application and for cleaning and sanitizing)
Water Test Requirements:
- For Public Water: No test required, you need to have a copy of the report from the municipality.
- For well water: You must test just wells used for harvest and post-harvest four times in the first year and then if there is no detectable generic E. coli on any tests you may test each well once per year after that initial year.
- For surface water: Untreated surface water is not allowed to be used for harvest and post-harvest purposes.
Compliance Dates:
- Large Growers (over $500,000): Currently in effect
- Small Growers ($250,000-$500,000): Currently in effect
- Very Small Growers ($25,000- $250,000): January 26, 2025
When complying a grower must inspect the agricultural water system that is under their control to determine any hazards. The water source test results must ensure that there is no detectable generic E. coli per 100 ml of water and untreated surface water cannot be used.
If a water test does not meet the criteria for non-detectable generic E. coli the farm must immediately stop using the water. The grower must take several steps before using the water including reinspecting the entire affected agricultural water system, under their control and make corrections or treat the water.
There are other required measures including having a water change schedule; visually monitoring the quality of water (for buildup of organic material) and monitoring the temperature of certain commodities.
The records required include the agricultural water system inspection; water test results; any water treatment; and corrective actions. Review Subpart E sections 112.41-112.48, 112.50, 112.151 and 112.161.
Pre-Harvest (Irrigation, Frost Protection, Sprays) Water
There is some confusion as to whether growers need to test their water for pre-harvest uses in 2024. The pre-harvest irrigation water requirement is still under review by the Food and Drug Administration, so testing is not required in 2024.
What we suggest you do now:
- For well water: Test once a year
- For surface water: Test three times a year. (when the pump is started, mid-season and close to harvest.)
This will give the grower a baseline as to the quality of water being used. When the final rule goes into effect the largest growers (over $500,000) will have nine months; small growers ($250,000-500,000) will have 1 year, and nine months and the very small growers ($25,000-250,000) will have two years and nine months to start complying.
Source: The On-Farm Food Safety Team (Meredith Melendez, Jennifer Matthews and Wesley Kline)
