Dr. Stoeckel is quick to say that water with fecal contamination is bad for produce safety, and that fact will not change.
“The main things that may change,” he says, “are how that fecal contamination is measured, and what steps are taken to protect produce safety based on the level of fecal contamination. Good Agricultural Practices call for analysis of generic E. coli in water used for fresh produce to detect fecal contamination, and farmers should continue that type of testing to help understand the quality of their water.”
Farmers are adaptable, and Dr. Stoeckel has no doubt they will be able to adapt to and meet requirements necessary to produce safe and healthy food. However, farmers need to understand the changes FDA is implementing and the reasoning behind them—which is why it was important to discuss and simplify the rule.
“All of us will benefit from plain language […] from FDA to explain compliance strategies for any new requirements,” he says. “Given sufficient time, and support (education, financial, infrastructure), the farms will be able to meet the requirements.”
The next steps will be FDA’s. The federal agency came away from the meeting last year with information from stakeholders across the industry about their needs, and Dr. Stoeckel says he trusts FDA will build on that knowledge to “re-evaluate and possibly alter the requirements of Subpart E.”