Jul 10, 2018

Agriculture water testing methods updated by FDA

FDA has just updated the list of equivalent agricultural water testing methods. The new factsheet is attached, and also available online here.

• The produce safety rule landing page, in the right-hand column

https://www.fda.gov/food/guidanceregulation/fsma/ucm334114.htm

• The laboratory methods webpage

https://www.fda.gov/Food/FoodScienceResearch/LaboratoryMethods/ucm575251.htm

What’s so important about this update?

Last Sept. 11, FDA released a list of methods equivalent to EPA 1603, the prescribed method in the Produce Safety Rule, greatly expanding laboratory accessibility for testing your water. All of those methods (on page one of the factsheet) involved quantifying (i.e. determining the actual number of) E. coli present in a 100 ml water sample. Those tests needed to be used whether you were testing production (pre-harvest) water with the currently “challenging” Microbial Water Quality Profile of the Geometric Mean (GM) and Statistical Threshold Value (STV) or harvest and postharvest water (including ice, handwashing, and water used for cleaning) where the standard was simply no detectible E. coli in a 100 ml sample.

What this update has done (page 2) is provide equivalent tests for harvest and postharvest water (including ice, handwashing, and water used for cleaning) so that instead of quantifying (i.e. determining the actual number of) E. coli, now you can just test to see if E. coli is present or absent in the 100 ml water sample using one of the tests on the second page. The advantage of these tests are that they are often less expensive.

FDA has proposed delayed compliance dates for Ag Water (an additional four years beyond your compliance date to meet all other requirements), and continues to look at water related requirements of the Produce Safety Rule.