Bridging the GAPs: Approaches to Treating Water On Farms

well as food contact surfaces, requiring a higher microbial quality (no detectable E. coli per 100 ml water sample). This publication focuses on the treatment of agricultural production water used during growing activities. In March 2019, FDA published an extension of compliance dates for Subpart E (see Table 1). Within this text, the FDA extended ALL provisions of Subpart E (agricultural water) other than sprouts, including the safe and sanitary quality, annual inspection, and postharvest water monitoring requirements. The reasoning for this extension, as stated by the FDA, is to address questions about the practical implementation of compliance with certain provisions and to consider how we might further reduce the regulatory burden or increase flexibility while continuing to protect public health. Until the process of consideration is complete, the water requirements as written are the rule.

Table 1. Water compliance date extension.

Farm Size*

Compliance Date

Large Farms

January 26, 2022

Small Farms

January 26, 2023

Very Small Farms

January 26, 2024

*In 2011 dollars: Large farms: $500,000+; Small farms: $250,000-499,999; Very small farms: $249,999-25,000

Microbial Risks Associated with Agricultural Production Water

Within the Produce Safety Rule, the FDA states that “all agricultural water must be safe and of adequate sanitary quality for its intended use.” In food production, water can serve as a vector for both human pathogens, as well as plant pathogens in growing operations. Fruit and vegetables that come in contact with contaminated irrigation water can cause illnesses, and plant pathogens can spread via irrigation water leading to plant disease and yield losses. The Produce Safety Rule is focused on reducing the risk of human illnesses via fresh produce rather than plant pathogens. Irrigation water is one of the main sources of pathogenic contamination on produce. Irrigation water is typically sourced from groundwater, surface water, or, in a few cases, municipal sources. Surface waters potentially pose the highest risk, as they are exposed to environmental contamination, followed by groundwater, and municipal water having the least amount of risk. Agricultural production water, particularly surface water including streams, ponds, and lakes, that have been contaminated with feces, has the potential to carry pathogens such as bacteria, viruses, or parasites. The water can serve as a vector or a


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