Meeting Report: Key Outcomes from a Collaborative Summit on Agricultural Water Standards for Fresh Produce

Abstract

On February 27 to 28, 2018, the Produce Safety Alliance convened a national water summit in Covington, KY to discuss the requirements of the United States Food and Drug Administration's (FDA) Food Safety Modernization Act Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (Produce Safety Rule [PSR]). The goals of the meeting were to better understand the challenges growers face in implementing the requirements in Subpart E–Agricultural Water and work collaboratively to develop practical solutions to meet fruit and vegetable production needs while protecting public health. To meet these goals, the summit engaged a diverse group of stakeholders including growers, researchers, extension educators, produce industry members, and regulatory personnel. Key outcomes included defining implementation barriers due to diversity in water sources, distribution systems, commodity types, climates, farm size, and production activities. There was an articulated need for science‐based solutions, such as the use of agricultural water system assessments and sharing of federal, state, and regional water quality data, to ensure qualitative and quantitative standards reduce microbial risks. These identified challenges and needs resulted in significant debate about whether reopening the PSR–Subpart E for modification or attempting to address concerns through guidance would provide the best mechanism for alleviating concerns. In addition, training, outreach, and technical assistance were identified as vital priorities once the concerns are formally addressed by FDA. The water summit highlighted the critical need for transparency of FDA's progress on reevaluating the Subpart E requirements to help guide growers’ decisions regarding the use of agricultural water.

Complex Interactions Between Weather, and Microbial and Physicochemical Water Quality Impact the Likelihood of Detecting Foodborne Pathogens in Agricultural Water

“…Indeed, the US Food and Drug Administration proposed microbial water quality standards as part of the Food Safety Modernization Act's (FSMA) Produce Safety Rule. However, understanding and complying with the proposed standard while ensuring water availability has been cited in industry magazines and grower surveys as a challenge facing growers (Alexander, 2015;Dery et al, 2019;Wall et al, 2019). For example, interpretation of E. coli test results is complicated by temporal variation in microbial water quality (Goyal et al, 1977;Hipsey et al, 2008;Payment and Locas, 2011;Pandey et al, 2012).…”

Predictive Models May Complement or Provide an Alternative to Existing Strategies for Assessing the Enteric Pathogen Contamination Status of Northeastern Streams Used to Provide Water for Produce Production

“…Since outbreaks frequently result in consumer avoidance of the implicated food, there are both substantial public health and economic costs associated with outbreaks (Ribera et al, 2012;Hussain and Dawson, 2013;Hoffman, 2014). Heightened industry concerns surrounding the food safety risks associated with preharvest water use for produce production (Lewis Ivey et al, 2012;Schattman et al, 2018;Wall et al, 2019) are highlighted by a 2017 survey where 77% of the 155 Northeastern growers surveyed cited the need for irrigation practices that ensure produce safety as a key concern (Schattman et al, 2018). Since 70-80% of US growers rely on agricultural water (as opposed to rain) for irrigation (Rangarajan et al, 2002;Astill et al, 2018), water is integral to produce production.…”

“…The MWQP's 90th percentile and geometric mean E. coli level must be <410 and <126 CFU/100-mL, respectively (Food and Drug Administration, 2015). However, meeting these standards has been repeatedly cited as a critical concern among industry stakeholders (Calvin et al, 2017;Astill et al, 2018;Wall et al, 2019). Following a summit focused on grower concerns about the FSMA standard, summit organizers summarized these concerns as centering on the (i) cost of meeting the standard, (ii) value of E. coli-based tests for assessing risk, (iii) lack of data supporting the standard's water sampling frequency (e.g., 5 times/year for 4 years), and (iv) difficulties in accurately assessing risk due to the complexity of farm and freshwater environments (Wall et al, 2019).…”

“…However, meeting these standards has been repeatedly cited as a critical concern among industry stakeholders (Calvin et al, 2017;Astill et al, 2018;Wall et al, 2019). Following a summit focused on grower concerns about the FSMA standard, summit organizers summarized these concerns as centering on the (i) cost of meeting the standard, (ii) value of E. coli-based tests for assessing risk, (iii) lack of data supporting the standard's water sampling frequency (e.g., 5 times/year for 4 years), and (iv) difficulties in accurately assessing risk due to the complexity of farm and freshwater environments (Wall et al, 2019). Since this summit, multiple studies have validated each of these concerns (e.g., Calvin et al, 2017;Havelaar et al, 2017;Truitt et al, 2018;Weller et al, 2020a).…”

Complex interactions between weather, and microbial and physiochemical water quality impact the likelihood of detecting foodborne pathogens in agricultural water

“…The proposed standard states that E. coli levels in surface water directly applied to preharvest produce cannot exceed a geometric mean of 126 CFU/100-mL and a statistical threshold value (STV) of 410 CFU/100-mL; these values are calculated using 20 samples collected over a 2 to 4 year period. However, understanding and complying with the proposed standard while ensuring water availability has been cited in industry magazines and grower surveys as a challenge facing growers (Alexander, 2015; Dery et al, 2019; Wall et al, 2019). For example, interpretation of E. coli test results is complicated by temporal variation in microbial water quality (Goyal et al, 1977; Hipsey et al, 2008; Pandey et al, 2012; Payment and Locas).…”