Water Used in Crop Production
Answer reach of the following questions in order. You will use this information to prepare your manual.
1. In the field, do you irrigate, cool, apply protective sprays (such as pesticides) or use any agricultural water during the production of fresh produce?
Yes –go to number 2.
No - If you do not use any water in the field while growing fresh produce, there is no applied water risk. Note this situation in your food safety plan.
2. Do you have a map that shows your water source(s) and the distribution system for you farm?
Yes – go to number 3.
No - Create a map (can be hand drawn) that shows the location of your water sources and how water is distributed throughout your farm from those sources. Note the irrigation method and other distribution details on the map and in your manual. This information will also help you assess risks related to water distribution.
3. Do you inspect your water sources at the beginning of production and throughout the growing season in the required frequency?
Yes – go to number 4.
No - All water sources must be inspected at the beginning of the growing season, and periodically thereafter. Surface water sources, such as ponds, rivers, and streams, must be inspected for the presence of wildlife and adjacent land issues that could lead to contamination of the water source. Well casings must be inspected to make sure they are intact and well recharge areas must be free of risks. Any identified risks must be addressed before the water source is used for fresh produce production.
4. Do you inspect your water distribution or delivery system, including equipment, at the beginning of the growing season and routinely thereafter?
Yes – go to number 5.
No – Inspecting before and during the growing seasonensures that the lines are clear and not likely to introduce microbial contaminants. Preventive maintenance must be performed as needed.
5. Is all water used in crop production tested (as required) for the presence of generic E.coli?This includes water used to mix protective sprays such as pesticides.
Yes –go to number 6.
No – All water used in crop production must meet the requirements of the FDA when the proposed rules are approved in the future. The proposed rule states that water (including ice) used for any purpose that contacts the crop during or after harvest must not have detectable levels of generic E. coli. Water used for cleaning food-contact surfaces and hand washing must also be free of detectable levels of generic E. coli.
The proposed rule says that water that contacts the crop during the growing period cannot have more than 235 CFU(or MPN) of generic E. coli per 100 mL in any single sample or the water cannot have a rolling mean (n=5) of more than 126 CFU (or MPN) of generic E. coli per 100 ml. If your irrigation method (drip, furrow, subsurface) prevents the water from contacting the harvestable portion of your crop during the growing period, then you do not need to test the water under the FDA Proposed Rule.
The proposed rule states that the frequency of water testing depends upon the source type. If your water comes from a Public Water System that meets the requirements of the federal Safe Drinking Water Act, you don’t need to test it as long as you have a copy of the most recenttest results provided by the water supplier. If your water comes from a sealed well, you must have the water tested at the beginning of the season and then every three months thereafter. If your water comes from a surface source such as a stream, river, lake or pond fed by runoff, you must have the water tested at the beginning of the season and at least weekly thereafter. If the water source is a surface-water containment (such as a reservoir) fed from an underground aquifer, the testing must be done at the beginning of the growing season and at least monthly thereafter.
You must be able to verify your testresults, therefore it is best to use a licensed laboratory.
6. Do you keep records of all water test results and water management actions, such as inspecting water sources and water delivery systems?
Yes – this risk analysis is complete.
No - Records must be kept for all water tests as well as any water management actions taken to identify and reduce risks that may be present in the water or the water delivery system.