Postharvest Water Requirements for Packers

Josh McGillPacking, Regulation, Tip of the Week

By Clara Diekman, Micah Gallagher, Taylor O’Bannon and Michelle Danyluk

Compliance dates for all water associated with the Produce Safety Rule (PSR, Subpart E) has previously been delayed, pending completion of the rule. The U.S. Food and Drug Administration (FDA) announced in the fall of 2022 that postharvest water requirements in the PSR will be enforced on large farms beginning Jan. 26, 2023. Small farms will have an additional year, and very small farms will have an additional two years to implement the requirements.

Postharvest water includes water used in packinghouses to wash or rinse citrus.

Postharvest water is water used during and after citrus harvest that contacts, or is likely to contact, citrus or fruit contact surfaces. Examples include water used to wash or rinse citrus, water used for fungicide drenches, water used during the cleaning and sanitation of tools and equipment, and handwashing water.

Postharvest water requirements include that packers need to perform and document an annual inspection of their agricultural water systems. This includes water sources, water distribution systems, facilities and equipment. Packers must consider the following when assessing their water system:

  • The nature of the water source (for example, ground or surface water)
  • The extent of control over the water source
  • The degree of protection of each water source
  • Use of adjacent and nearby land
  • The likelihood of contamination occurring before the water reaches the farm

Regular inspection of system equipment will help identify any problems and/or areas that need maintenance to help prevent the distribution system from becoming a source of contamination. Things to look for include adequately maintaining all agricultural water distribution systems, including backflow devices, hoses, pipes and other equipment.

Packers must also adequately maintain all agricultural water sources under their control. Maintenance-related hazards such as repairs to a well cap, well casing, sanitary seals, treatment equipment, and control of cross-connections must be identified and corrected when necessary.

Water used during harvest and postharvest must have no detectable generic Escherichia coli in 100 milliliters. Untreated surface water must not be used during postharvest activities. If packers are using untreated groundwater (i.e., well water), they must test the water at least four times during the initial season and at least once annually thereafter. The rule does not require water sourced from a public water supply to be tested, but packers must have a certificate of compliance or water testing results from the municipality.

Packers are not required to use sanitizers under the PSR. However, sanitizers can be used as a tool to manage water quality and prevent cross-contamination of microorganisms. This is especially important in recirculated water systems. Visual inspection to monitor the organic matter buildup and establishing a schedule for changing recirculated water is required. Records required for compliance include:

  • Results from annual agricultural water system inspection
  • Water test results or annual documentation of results/certificates of compliance from public water system
  • Water treatment/sanitizer monitoring log results

All records and documentation must be reviewed, dated and signed by a supervisor/responsible party within a reasonable timeframe upon filling out records.

The University of Florida Institute of Food and Agricultural Sciences (UF/IFAS) and the Florida Department of Agriculture and Consumer Services are hosting a webinar and question-and-answer session on postharvest water compliance Jan. 19. Attendance is free, and pre-registration is available here.

For more information about the upcoming compliance dates and agricultural water requirements, visit these FDA web pages:

Clara Diekman is an education and training specialist, Taylor O’Bannon is a state food safety Extension agent, and Michelle Danyluk is a professor — all at the UF/IFAS Citrus Research and Education Center in Lake Alfred. Micah Gallagher is an education and training specialist at the UF/IFAS Department of Food Science and Human Nutrition in Gainesville.

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