This past May, the FDA released their final pre-harvest water regulation, which governs how fresh produce growers use water before they begin harvest. Growers who are subject to inspections by Michigan Department of Agriculture must still manage their pre-harvest water in a manner that will not endanger the public when they eat produce. However, how they assess their water quality has changed.
The updated pre-harvest water rule changes the overall approach from depending on water testing to an approach where growers must assess hazards that could affect the quality of their water source(s). Growers are responsible for assessing these hazards on their farm and in areas next to and nearby the water sources they use. If a hazard is identified that could negatively impact the quality of the water used in pre-harvest activities, growers are required to mitigate these hazards to ensure water is safe for it’s intended use. Testing can still be used as part of this assessment, but a grower can no longer rely solely on water tests to prove compliance with the law. This is not an easy shift and will likely require more learning than can be presented in an article or video.
Rest assured that the Michigan On-farm Produce Safety Team has your back! Here are three ways we can help you learn more about the new pre-harvest water rule requirements.
Come talk with us! We will be focusing on water at most of the winter produce meetings, including Great Lakes Expo, MPIC Annual Meeting, Northwest Orchard and Vineyard Show and Southwest Horticulture Days. We will also continue working with various industry groups to dive deeper into how the new requirements affect growers and how we can support growers as they work towards compliance.
Consider attending a PSA Grower Training - even if you have attended one before. The pre-harvest water module in the Produce Safety Alliance Grower Training has been updated to reflect the finalized rule. This module provides much more detail about the new pre-harvest water requirements and what growers will need to do. Attending one of the trainings, remote or in-person, will help you understand the new requirements and refresh your memory about the stuff you may have forgotten. For growers that need continuing education credits for a GAP audit – the PSA Training is a great option!
To learn more about the dates and cost to attend a PSA Training, click the link below. If cost is a barrier to attend, consider applying to your local FSA office for a cost share of the expenses associated with the training.
Schedule a time for us to visit your farm. An On-farm Readiness review or a farm consultation with MSU Extension and your local Produce Safety Technician is a free and easy way to learn more about the new requirements. We can walk step-by-step through the requirements and apply them directly to YOUR situation! To schedule a visit, email Heather at bordenhe@msu.edu.
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Article by Phil Tocco, MSU Extension Educator