demonstrate efficacy against foodborne pathogens and indicator organisms within the label. Many registered antimicrobial products are labeled as antimicrobial washes for use during postharvest fruit and vegetable washing. Because these products are not labeled for EPA use for irrigation water, they cannot be used to treat irrigation water that is applied prior to harvest. Pesticide devices or non-chemical treatments, are also regulated by the EPA, but do not require EPA registration. While they do not requi re federal registration, devices are regulated in that “false or misleading claims” cannot be made about their effectiveness. A manufacturer of a pesticide device that is regulated will have an EPA establishment number even though the device itself is not registered. Pesticide devices must meet the EPA definition as follows: an instrument or contrivance other than a firearm (or medical device) that is used to destroy, trap, repel, or mitigate (lessen the severity of) any pest such as insects, weeds, rodents, birds, mold/mildew, bacteria, and viruses.
The EPA oversees or regulates the approval of antimicrobial pesticides, and many devices. Following the label assures compliance with the law regarding safe use, avoiding adverse health effects to humans and the environment.
While treating irrigation water is not a requirement under the FSMA Produce Safety Rule, it may serve as an effective preventive strategy and risk reduction measure to lower microbial contamination in water. This treatment can be implemented using either an EPA-regulated chemical or device as a corrective measure for production agriculture water. These treatments must be used in accordance with the EPA label and instructions. While there is no EPA-approved chemical treatment of production agricultural water for reducing microorganisms of food safety concerns, current studies may exist for setting limits for control of foodborne pathogens or indicators (E. coli).
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