One of the most important issues to address is the corrective actions to take in regards to the product or produce that may have been exposed to untreated water. The following steps outline actions a grower should take: 1. Determine if there is a risk with the untreated water. Once a deviation has occurred, collect a water sample and have it tested for generic E. coli to better understand the microbial quality of water. A grower may find that the levels of microbial populations of indicator organisms (generic E. coli ), provide evidence of a low probability of risk for pathogenic contamination.
2. Identify and correct the problem as soon as possible.
3. Determine what to do with the produce that has been exposed to untreated water. If the results of the water test result in high microbial counts of generic E. coli, the produce that came in contact with the contaminated water must be addressed. Options include applying another corrective measure. The following could be applied: 1. Time interval between application and harvest. This must be validated with scientific literature that supports this approach. Determining the quality of water through aforementioned testing will be critical to understand the length of the time interval to apply. According to the Produce Safety Rule, the reduction is based on expected rates of microbial die-off in the field (0.5 log/day for up to four days), or during storage, or removal during processes such as commercial washing (scientifically validated die-off or removal rate must be supported with documentation).
2. Divert the produce for an alternative use, such as a processing step that applies a kill step for microbial reduction of pathogens of public health concern.
3. Destroy and dispose of produce if other corrective measure or diversion is not possible.
4. Reduce the likelihood of recurrence through an extensive root cause analysis to determine the true cause of the deviation. While fixing the problem is obviously an important step, determining the true cause of the deviation will likely require some detective work. For example, if the hose was disconnected on the chlorinator, a grower should determine what caused the disconnection, i.e., a cracked seal? employee error?, etc.
Document all corrective actions taken.
The responsibility for decision-making should be clearly defined during the assignment of monitoring responsibilities. It is ideal to train the individual responsible for monitoring on proper corrective actions to take in the instance a critical limit is not met (deviation). The individual should at least be trained on who to report to in case of a deviation.
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