adequate for intended use” means that it meets or exceeds the standards for recreational water as measured by testing for generic E. coli and monitoring for shifts in baseline levels. Recent research and outbreaks have taught us there are inadequacies in the current ag water quality management strategies and that change is necessary. First, generic E. coli is inconsistent, and therefore ineffective, when used as the sole indicator for the presence of pathogens, such as E. coli O157:H7, in ag water sources. In addition, not all ag water from all sources are of equivalent food safety risk—a municipal source or a deep, protected well do not present the same risk as surface waters. Historically, we have attempted to account for the quality of water systems by testing water as close to the point of use as possible. But the manner in which water is stored and conveyed can be a significant contributor to the safety of the system and warrant separate assessment and evaluation. In reality, it is the water source + the storage of water + the conveyance system used that dictate the water’s ultimate “fitness for use.” Any new paradigm must consider all these factors, provide metrics to assist with their evaluation and spell out best practices to ensure system integrity. The metrics currently being drafted and discussed are intended to prioritize risk by classifying ag water into two systems designated for specific uses within leafy greens operations. In essence, we are asking individuals to assess their water sources, storage, and conveyance and then categorize water systems as Type A or Type B. A Type A system is one in which the source water is known to be free from fecal contamination (such as a municipal, regulated reclaimed, tested deep well or verified treatment supply) that is then stored and conveyed in a manner that does not expose the source to the outside environment. Water from Type A systems can be used in any irrigation scenario including overhead irrigation close to harvest.
A Type B system would essentially be all other water and its uses would be restricted. For example, a surface water source stored in an open reservoir and then pumped into a sprinkler set could not be used within 21 days of harvest. These are examples of how the water source + the storage + the conveyance must be fully evaluated to determine the “fitness for use” or that water is “safe and adequate for its intended use.” Of course, there is much more that must go into the development of a new ag water paradigm, but the high-level concept is sound. And incorporating industry-led changes into the LGMA requirements is the most effective way of changing practice in the field, which is what many are trying to do. This raises the final point of concern: It is not ideal to move into siloed activity to address these outbreaks and improve our preventive programs. As a result of the most recent outbreak, the United/PMA Task Force has been created, regional groups have formed to address issues, and select parts of the supply chain have grouped together to suggest change. In the spirit of “hang together or hang separately,” it seems a better model should be developed and institutionalized going forward. In recent discussions the concepts of a “strike team” or a National Transportation Safety Board-style team has been offered, and I suggest this could be as simple as organizing a standing group of association leaders representing all aspects of the supply chain that meets and coordinates action every time there is an outbreak. It is an extra and unneeded chore to try to coordinate all the siloed efforts underway today. As trade organizations, I proposed that when it comes to consumer safety, we get over our need to individually demonstrate value and come together to make a difference for the industry and the consuming public that we serve.
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MARCH | APRIL 2019
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