Dr. LaBorde says, “It always comes back to: ‘Are you really sure that it’s the best way to be certain the water is safe for its purpose?’”
We may not have very many answers right now, but the shortest route to better practices is discussion, says Posy. “There is a real disconnect between the food safety community and the water safety community, both on the government and food processor/supplier/grower sides,” she says. “There’s even less dialogue on the discharge/recharge side. We need more dialogue and forums.”
For Ozeran, getting irrigation safety right comes down to developing high-level policy that balances scientific evidence, industry capacity, and pre-existing practices in the industries in question.
“For instance, if an industry is already implementing the best available practices but still experiencing food contamination,” she says, “then we need to support additional research to identify better ways to reduce contamination risks. If new policies cannot be implemented, or lack scientific support, then those policies will not improve food safety.”
The Food Safety Modernization Act carries with it a set of regulations pertaining to produce and agricultural water, but for Dr. McEntire it’s important to remember those regulations reflect minimal standards for a marketplace that has internal requirements generally exceeding those demanded by regulation, and often more frequently inspected.
“Most growers are subject to one or more annual food safety audits that include requirements around agricultural water,” says Dr. McEntire. “In California and Arizona, most producers are part of the Leafy Greens Marketing Agreements. Those water testing requirements go above and beyond the requirements in the Produce Safety Rule.”
Dr. LaBorde considers various factors that come into play, such as the increasing public appetite for raw produce, as well as the practice of irrigating with overhead sprayers, which douse produce in water.
“There are lower risk types of application methods such as drip or burrow irrigation,” he says, “which can be designed such that it wouldn’t contact the crop, reducing a lot of risk. That’s possible in very large farms. A lot of people who use drip irrigation here in Pennsylvania are small- or medium-size farms.”
Dr. LaBorde is also paying attention to studies on time-before-harvest, which aim to determine whether leaving produce in the sun will kill off enough pathogens to get produce down to safe levels. “That’s not always practical either because sometimes you have to water the crop just before harvest.”
He’s open to any new ideas about irrigation safety, but that openness is tempered by a clear understanding of how many factors come into play in trying to keep agricultural water safe. Dr. LaBorde—and many others—are as quick to dismiss silver-bullet thinking with real-world challenges.
The problem with irrigation safety, Dr. LaBorde concludes, is, “There aren’t a lot of easy answers.”
Compliance Dates for Agricultural Water Extended
FDA issued a rule on March 15, 2019 to finalize the new compliance dates for the agricultural water requirements in the FSMA Produce Safety Rule. Larger farms are now required to comply by Jan. 26, 2022, while small farms have until Jan. 26, 2023 and very small farms until Jan. 26, 2024. This rule does not change the compliance dates for sprout operations.—FQ&S