Agricultural Water

General

Produce Safety Alliance

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

Videos
FSMA: Preparing to Collect Water Samples
FSMA: Aseptic Water Sampling
FSMA: Annual Inspection
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