Crop Advisers Should Help Growers with Onerous Ag-Water Mandates

Micro-climate modification from surface water sources is included in the FSMA definition of agricultural water. (Photo credit: Trevor Suslow)

“Farming looks mighty easy when your plow is a pencil, and you’re a thousand miles from the corn field.”
— Dwight D. Eisenhower, Sept. 11, 1956

We’ve this quote popping up a lot recently in regards to the frustrations which naturally and inevitably seem to arise when federal policy and trade decisions or new regulations impact farm enterprises or specific regions or commodity groups. To paraphrase and modernize this quote from our 34th President, crop management challenges seem straightforward when Googling information on a computer in a cubicle in a monolithic building far removed from furrow, vineyard or orchard.

One of these current sweeping issues of concern revolves around the Agricultural Water definitions and provisions of the Food Safety Modernization Act (FSMA) Produce Safety Final Rule (PSR). Agricultural water is defined in part as “water (that is) intended to, or is likely to, contact covered produce or food contact surfaces” and covered produce is defined in part as “the harvestable or harvested part of the crop.” To ensure the proper context is provided, the Agricultural Water (ag-water) quality requirements detailed in the FSMA PSR only apply to farms covered by the rule that are using water that directly contacts the edible portion of the crop during growing activities, or during and after harvest activities.

Numerous grower meetings and training sessions directly related to the PSR have made it clear that confusion and frustration about the specific compliance expectations remain a hot-button topic in the fresh produce farming community. This is dramatically true for those farms where surface water sources are the main or only option for crop irrigation, frost protection, micro-climate management, and other diverse purposes which meet the above FDA definition for covered produce.

However, in reality, FDA did hold multiple listening sessions and many aspects of the final ruling are far less onerous than originally proposed. In addition, FDA is hard at work integrating industry, state agency, and academic feedback into guidance to better explain measures to ensure grower compliance and better position the allowed options for meeting expectations.

My purpose in this column is not to explain the details of the required on-farm ag-water quality profile baseline establishment or the substantial current barriers to meeting the testing criteria in many production regions. There are many resources available to help with understanding where things stand today, in grower-friendly language, such as an explanatory document from the Produce Safety Alliance called “FSMA Produce Safety Rule Water Requirements: Insights to Get You Organized!” at https://is.gd/FSMAPSAGetOrganized.

Monitoring surface water sources, turn-outs and gates for hazards which could impact water quality compliance needs frequent attention. (Photo credit: Trevor Suslow)

Opportunity Abounds
Rather, I would like to highlight an opportunity I have been sharing with crop management consultants every chance I get for many years, since the emergence of Good Agricultural Practices audit programs, related to expanding their value-added services to growers of row, vine, and tree crops.

As far as I am aware, crop and pest management service providers have taken very limited and tentative opportunities to offer services in food safety compliance programs. Some key fee-for-service or value-added service add-ons, at least in my opinion, would relate to PSR ag-water compliance provisions including observational scouting, mapping, sampling, chain-of-custody transport of samples, documentation, and other data reporting and record-keeping requirements.

For many growers, already juggling many regulatory requirements from an increasing alphabet soup of local, state, federal, and international trade agencies, the current ag-water compliance requirements are a handful.

They include details of calculating geometric means, statistical threshold value, and post-irrigation die-off allowance, and keeping up with evolving guidance and standards of optional equivalency programs looming on the horizon. Impending compliance dates are realistically for PSR ag-water not until January 2020 for larger operations and January 2022 for very small operations. If you have no idea what I am talking about, these are all explained in the Produce Safety Alliance link provided above.

In Your Wheelhouse
My main point here is that many of these functions could fit into services provided by crop and pest management specialists who spend time in vineyards, orchards, and groves sampling, collecting, observing, and walking the farm. These services could replace or supplement and, potentially, greatly reduce incremental costs to growers over the cost of sampling by the micro-testing lab. This is especially true in more remote areas far from urban or major produce production centers.

Perhaps a more important value would be ensuring an organized and standardized system for water quality compliance for farm operations not in a position to have dedicated food safety staff. In addition to ag-water, crop consultants could be in a good position to offer add-on services in observational documentation of domesticated animal and wildlife activity and intrusion into production areas. This is another key challenge under the PSR and consultants could play a major role in innovating effective measures to minimize intrusion.

In general, it is my hope we see far more engagement among the certified professional crop consultants in food safety management across the industry in 2017. At least it seems a missed business opportunity to me.
Next time I will be highlighting the new Produce Facts App for iPhone which the Postharvest Technology Center will be rolling out in the first quarter of this year.

Topics: ,

Leave a Reply

Food Safety Stories
multiple hands holding a plate full of veggies
Citrus
August 27, 2017
USDA Releases Software to Help Small Operations with Food Safety Plans
While the free tool was primarily designed for use by small firms, any size manufacturer can opt to use it. Read More
Citrus
August 23, 2017
Advice From the FDA on How Growers Can Keep Their Produce Safe
Want tips that will keep your operation on the right side of the FDA when it comes to food safety? American Vegetable Grower® decided the best advice would come directly from the FDA itself.  Read More
Farm Management
August 11, 2017
Vegetable Growers’ Food Safety Vigilance Is Paying Off (Opinion)
When you hear about recalls, the horror stories come to mind first. That’s understandable, considering the human cost involved with Read More
Citrus
August 9, 2017
Traceability Products to Help You Track Produce
One way to ease the process of a food safety recall is by having detailed records of where each crop has been and who has touched it. Look over these traceability products using the latest technology to help you stay on top of your records. Read More
Citrus
August 2, 2017
Recalls Happen. Here’s What You Can Do If It Happens to You
Follow this 10-Step plan to protect the public — and your farm. As a bonus, see how Duda Farms runs its mock recalls. Read More
Citrus
August 2, 2017
Perdue Appoints Key Food Safety Leaders
Carmen Rottenberg has been appointed Acting Deputy Under Secretary for Food Safety, and Paul Kiecker has been named Acting Administrator for the Food Safety and Inspection Service (FSIS). Read More
Food Safety
June 21, 2017
Organization Seeks Winegrape Exemption Produce Safety Rule
California Association of Winegrape Growers says because winegrapes are grown for processing, they should be exempt from produce safety rule. Read More
Citrus
June 9, 2017
Agriculture Water Standards Compliance Dates Extended
FDA says the agency will extend the compliance dates after feedback from stakeholders. Read More
Food Safety
April 12, 2017
No Need for Hysteria Over Reports of Listeria in Romaine Lettuce
A recent Purdue study says current food safety practices aren't killing listeria in romaine lettuce tissue. Rutger's Richard VanVranken says the report isn't as alarming as it sounds. Read More
Felipe-Gallardo-harvesting-collard-greens-at-Buurma-Farms
Farm Management
April 12, 2017
Take the Stress out of Food Safety Inspections
Buurma Farms has a low-tech, common sense system in place that keeps its produce as safe as possible, and makes passing inspections easy. Read More
Business Planning
March 22, 2017
How HortTech Is Solving Grower Challenges
Dozens of tech companies are looking for solutions to real-world problems vegetable growers face. We take a look at what it could really mean for you and your business. Read More
Citrus
March 15, 2017
Group Wants To Streamline Food Safety Regulations
There are 15 federal agencies implement more than 30 different food safety statutes. A team of experts believe they have a solution. Read More
Food Safety
March 10, 2017
Strawberries, Spinach Top Latest ‘Dirty Dozen’ List
Industry groups dispute annual report, noting any report that has the effect of decreasing Americans’ fruit and vegetable intake is injurious to their health. Read More
Cucurbits
March 8, 2017
How Steam Helps Remove Pathogens on Cantaloupes
The technique also may effectively sanitize watermelons, honeydews, cucumbers, and baby carrots. Read More
Food Safety Modernization Act moving at snail's pace
Food Safety
February 21, 2017
Food Safety Modernization Act Creeping Forward
Massive regulatory overhaul unfolds as the specialty crop industry hopes to ensure common-sense food safety rules and inspection. Read More
The Latest
Citrus
November 7, 2017
Comments Sought in Ag Water Component of…
Growers and other interested parties are encouraged by United Fresh to weigh in on agricultural water requirements in the Food Safety Modernization Act. Read More
Food Safety
October 29, 2017
FDA Hosts New Web Page for Key FSMA Date…
Dates of compliance are listed in order of when they should be followed. Read More
Citrus
September 13, 2017
New Guidance on FSMA Ag Water Compliance…
FDA issued a rule to extend compliance dates for agricultural water and announced a start date for farm inspections. Read More
Citrus
August 27, 2017
USDA Releases Software to Help Small Ope…
While the free tool was primarily designed for use by small firms, any size manufacturer can opt to use it. Read More
Citrus
August 23, 2017
Advice From the FDA on How Growers Can K…
Want tips that will keep your operation on the right side of the FDA when it comes to food safety? American Vegetable Grower® decided the best advice would come directly from the FDA itself.  Read More
Farm Management
August 11, 2017
Vegetable Growers’ Food Safety Vigilance…
When you hear about recalls, the horror stories come to mind first. That’s understandable, considering the human cost involved with Read More
Citrus
August 9, 2017
Traceability Products to Help You Track …
One way to ease the process of a food safety recall is by having detailed records of where each crop has been and who has touched it. Look over these traceability products using the latest technology to help you stay on top of your records. Read More
Citrus
August 2, 2017
Recalls Happen. Here’s What You Ca…
Follow this 10-Step plan to protect the public — and your farm. As a bonus, see how Duda Farms runs its mock recalls. Read More
Citrus
August 2, 2017
Perdue Appoints Key Food Safety Leaders
Carmen Rottenberg has been appointed Acting Deputy Under Secretary for Food Safety, and Paul Kiecker has been named Acting Administrator for the Food Safety and Inspection Service (FSIS). Read More
Food Safety
June 21, 2017
Organization Seeks Winegrape Exemption P…
California Association of Winegrape Growers says because winegrapes are grown for processing, they should be exempt from produce safety rule. Read More
Citrus
June 9, 2017
Agriculture Water Standards Compliance D…
FDA says the agency will extend the compliance dates after feedback from stakeholders. Read More
Food Safety
April 12, 2017
No Need for Hysteria Over Reports of Lis…
A recent Purdue study says current food safety practices aren't killing listeria in romaine lettuce tissue. Rutger's Richard VanVranken says the report isn't as alarming as it sounds. Read More
Farm Management
April 12, 2017
Take the Stress out of Food Safety Insp…
Buurma Farms has a low-tech, common sense system in place that keeps its produce as safe as possible, and makes passing inspections easy. Read More
Business Planning
March 22, 2017
How HortTech Is Solving Grower Challenge…
Dozens of tech companies are looking for solutions to real-world problems vegetable growers face. We take a look at what it could really mean for you and your business. Read More
Citrus
March 15, 2017
Group Wants To Streamline Food Safety Re…
There are 15 federal agencies implement more than 30 different food safety statutes. A team of experts believe they have a solution. Read More
Food Safety
March 10, 2017
Strawberries, Spinach Top Latest ‘…
Industry groups dispute annual report, noting any report that has the effect of decreasing Americans’ fruit and vegetable intake is injurious to their health. Read More
Cucurbits
March 8, 2017
How Steam Helps Remove Pathogens on Cant…
The technique also may effectively sanitize watermelons, honeydews, cucumbers, and baby carrots. Read More
Food Safety
February 21, 2017
Food Safety Modernization Act Creeping F…
Massive regulatory overhaul unfolds as the specialty crop industry hopes to ensure common-sense food safety rules and inspection. Read More