General
- FDA Launches Agricultural Water Assessment Builder to Help Farms Understand Agricultural Water Proposed Rule Requirements (FDA, March 21, 2022)
- FDA Proposes Changes to Food Safety Modernization Act Rule to Enhance Safety of Agricultural Water Used on Produce (FDA, Dec. 2, 2021)
- FDA finalizes new compliance dates for agricultural water requirements (FDA, 2019)
Produce Safety Alliance
- FSMA Produce Safety Rule: Agricultural Water Systems Inspection is Different from the Agricultural Water Assessment (PSA, Feb. 2025) (PDF 235 KB)
- Geometric Means, Statistical Threshold Values, and Microbial Die-Off Rates (PDF 579 KB)
- Water analysis method requirement (PDF 192 KB)
FDA updated the guidelines for Pre-Harvest Agricultural Water (Subpart E) in the FSMA Produce Safety Rule (PSR) on May 6th, 2024. This revision to Subpart E brings some significant changes to how growers need to monitor and manage pre-harvest agricultural water during growing activities. The revisions also include renaming "production water" to "pre-harvest water”.
Under the prior PSR rule, growers had to create a Microbial Water Quality Profile (MWQP) for each untreated water source used in their operations, with a focus on measuring generic E. coli levels. This means growers were required to assess microbial contamination levels in agricultural water, especially since water can be a key vehicle for foodborne pathogens.
The revised Subpart E requirements shift the focus from routine pre-harvest water testing to a more comprehensive agricultural water assessment. This assessment evaluates the entire agricultural water production system, considering factors such as:
- The quality and use of agricultural water
- Environmental conditions
- The characteristics of the crops being grown, and
- Risks from adjacent or nearby land uses.
Pre-harvest water testing is still included, but it now serves as one of several tools to inform a farm’s overall risk assessment, rather than being the primary compliance requirement.
The expectation is that each grower understands their water quality and how their water management practices minimize risks to the crops they grow. We encourage you to visit the FDA FSMA Final Rule on Pre-Harvest Agricultural Water page for current information.
The updates also include additional resources to help producers understand these changes and to better guide compliance efforts.
Microbial Water Quality Profile (MWQP) for Agricultural Water
Resources
- Environmental Assessment / System Inspection Questionnaire (Bond-Partyka, 2020 Western Center for Food Safety) (PDF 280 KB)
- From United Fresh Produce Association: United Fresh’s Food Safety Council and Harmonized Calibration Committee agreed that the industry would benefit from a document that a grower can use to guide their thought process through the assessment of their agricultural water risk. The following document is a compilation of existing resources and approaches developed by the volunteer workgroup.
- Testing Agricultural Water for Fruit and Vegetable Production and Postharvest Handling (Washington State University) (Click to download; PDF is 3.3 MB)
- Dufour, A. P. and S. Schaub. The Evolution of Water Quality in the United States- 1922-2003. Chapter 1, L. J. Wymer (ed.), Statistical Framework for Recreational Water Quality Criteria and Monitoring. John Wiley and Sons, LTD, , Uk, , 1-12, (2007)
- USEPA Health Effects Criteria for Fresh Recreational Waters. EPA 600/1-84-004 (1984)
- USEPA Ambient Water Quality Criteria for Bacteria – 1986. EPA 440/5-84-2 (1986)
- USEPA Recreational Water Quality Criteria. Office of Water 820-F-12-058 (2012)
- FDA FSMA Final Rule for Produce Safety: How Did FDA Establish Requirements for Water Quality and Testing of Irrigation Water? (2015)
- FDA Fact Sheet Equivalent Testing Methodologies for Agricultural Water (2018)
- LGMA Metrics, Appendices, and Guidance documents
- Agricultural Water for Production: National GAP (CornellCALS)
Videos