The Food Safety Modernization Act’s regulations were developed to proactively address food safety.  Impacts of these regulations will be far-reaching and have already changed food safety management within operations.  Some of the rules, such as those addressing produce safety, provide requirements to an industry where federal food safety regulations have, previously, been absent.  Therefore, the question of compliance and implementation is germane.   The area of “agricultural water” is one of the most vigorously debated parts of the Produce Safety Rule.  Some anxiety and obstacles have been triggered by the expectation that “it must be safe and of adequate sanitary quality for its intended use.” Evaluation of untreated agricultural water quality must be done through establishment of a microbial water quality profile, through representative samples by an indicator of water quality, specified as generic Escherichia coli; but allowance for qualified alternatives is available.  Finding labs accredited in U.S. EPA method 1603 or defining equivalent methods that could be used are outstanding shared barriers to implementation across many farms with "covered" produce.  Interestingly, many qualified exemption farms are already being required to implement this Produce Rule ag-water testing. When the required microbial water quality profile is not meet, treatment of water with an EPA labeled product is one of the allowed corrective measures. Many are having difficulty identifying what their treatment options are and determining what treatment system is appropriate for their operation. FDA guidance documents can provide further assistance for defining best practices, but there will be remaining obstacles.  This symposium will provide the critical hurdles and robust discussion for moving us towards required industry compliance under the Produce Safety Rule, in the areas of establishing microbial water quality profiles, corrective measures, and remaining areas for consideration, if we are to achieve the required compliance under this rule.

Presentations