Assessing the Safety of a Water Distribution System

By Taylor O’Bannon, Matt Krug and Michelle Danyluk

The U.S. Food and Drug Administration recently proposed changes to the pre-harvest Agricultural Water (Subpart E) section of the Food Safety Modernization Act Produce Safety Rule (PSR). Removing the annual water distribution system inspection is not one of the proposed changes. Rather, water testing for generic E. coli and developing a microbial water quality profile to determine if water meets quality standards, is replaced with pre-harvest water system assessments. At the top of the list of factors that must be assessed in the proposed changes is the agricultural water system.

Regardless of the outcome of the proposed changes, growers should know how to assess the safety of their water distribution system. Both the current and proposed rules require growers to assess the following when examining the safety of their water source:

The type and location of each agricultural water source (ground or surface water)
The extent of the farm’s control over each water source
The degree of protection of each water source
Use of adjacent land
The likelihood of contamination being introduced before the water reaches the farm

Growers who are using ground water on their operation should inspect their wells to ensure they are in good condition, capped and sealed properly. They should check for any signs of leaks or damage to the well and ensure back flow preventers are installed and working properly, and that there are no risks of contamination by animals or standing water. Growers using surface water for pre-harvest applications should assess its protection from possible risks including other users, wildlife and domesticated animals, and adjacent or nearby land uses.

The rule also requires that all water sources and distribution system components, including back flow prevention devices, pipes, hoses, nozzles, sprinkler heads, and distribution equipment, are inspected and maintained to prevent risks of contamination. All components should be kept free of trash and debris to prevent harborage of pests or microorganisms that could contaminate the water distribution system.

While the PSR only requires documented inspection of the water distribution system once annually, assessing the risks of water distribution systems can be built into the day-to-day activities on the farm. Workers who manage irrigation systems and spray tanks should be trained to identify and respond to risks. In many cases, these activities are already taking place, and recordkeeping of these activities can be added to monitor risks and meet the requirements of the PSR or third-party audits.

A downloadable Water Distribution System Log and other recordkeeping log templates can be found in the Recordkeeping Tool from the Florida Department of Agriculture and Consumer Services. On-Farm Readiness Reviews (OFRR) are another way growers can receive assistance with implementation of food-safety principles or the PSR on their farm. Visit www.fdacs.gov/OFRR to request an OFRR.

Contact UFFoodSafety@ifas.ufl.edu for more information about the PSR requirements or for help assessing water distribution system risks.

More details about the proposed changes to Subpart E of the FSMA Produce Safety Rule can be found here.

Taylor O’Bannon is a state food safety Extension agent, and Michelle Danyluk is a professor, both at the University of Florida Institute of Food and Agricultural Sciences (UF/IFAS) Citrus Research and Education Center in Lake Alfred. Matt Krug is a state food science Extension agent at the UF/IFAS Southwest Florida Research and Education Center, in Immokalee.