FSMA updates pre-harvest water risk rules

By Blake Jackson

The Food Safety Modernization Act (FSMA) has implemented a revised approach to ensure the safety of pre-harvest agricultural water used on certain crops. This article outlines the key points for farmers to navigate these changes.

Previously, FSMA mandated a fixed number of water samples regardless of a farm's specific context. The updated regulations prioritize a written water quality risk assessment tailored to each farm's unique situation.

Applicable Water Sources:

• Overhead irrigation systems
• Drip irrigation used for ground crops typically consumed raw (onions, garlic, etc.)
• Water employed for spraying or frost protection

Exempt Water Uses:

• Drip irrigation with plastic covering for above-ground crops
• Water utilized for post-harvest activities (washing, cooling, etc.) - regulations for these remain unchanged

Factors Influencing Risk:

• Water Source: Surface water (rivers, ponds) is generally considered higher risk compared to groundwater (wells).
• Application Timing: Water applied closer to harvest poses a greater risk. Irrigation before edible parts form is exempt.
• Application Method: Drip irrigation presents a lower risk than overhead irrigation.
• Crop Characteristics: Crops with crevices harboring bacteria (lettuce, cantaloupe) are higher risk than smooth-skinned fruits or crops grown off the ground.

Ensuring Compliance:

Farmers should evaluate these factors to determine their risk level and implement any necessary corrective actions. Resources such as standardized checklists and decision trees are expected to be developed to help conduct risk assessments. Additionally, extension workshops are likely to be offered in the coming winter to provide further guidance.

Compliance Timeline:

• Farms exceeding $500,000 in sales: Compliance deadline - April 7, 2025
• Farms exceeding $250,000 in sales: Compliance deadline - April 6, 2026
• Farms under $250,000 in sales: Compliance deadline - April 5, 2027

By understanding these revised regulations and conducting thorough risk assessments, farmers can ensure their irrigation practices align with FSMA's safety standards.

Photo Credit: istock-laughingmango