Ask These Questions When Conducting an Agricultural Water Assessment

By Michelle Danyluk, William “Billy” Mitchell, Stephanie Brown, Emmy Collins, Keith R. Schneider and Taylor O’Bannon

Most citrus growers have been meeting the Food and Drug Administration’s (FDA) Produce Safety Rule (PSR) requirements since 2016. However, changes to this rule in May of 2024 now require growers to have an agricultural water assessment (AgWa) for production (i.e., pre-harvest) water.

A tiered approach to compliance is underway. Larger businesses were required to comply by April 7, 2025. The small business (>$250,000 to $500,000) date was April 6, 2026. Very small businesses (>$25,000 to $250,000) must comply by April 5, 2027. The University of Florida Institute of Food and Agricultural Sciences (UF/IFAS) Produce Safety Team works with growers to help them meet this new requirement. Tools and record-keeping templates help document an AgWa. (See https://resources.producesafetyalliance.cornell.edu/documents/Records-Required-by-the-FSMA-PSR.pdf, page 10-11).

Below are questions to help citrus growers create an AgWa, decide if changes are needed to water use and prepare for a PSR inspection. With recent outbreaks linked to pre-harvest water and new regulatory requirements, this should be a priority!

1. Where is your citrus being sold? If it is being sold to the fresh market, you may need an AgWa. If it is only going to a processor (e.g., for juice production), the FDA will not require you to have an AgWa. However, your buyer may still request an AgWa.
2. Do you use agricultural water? In the context of the PSR, agricultural water is any water that is likely to or intended to contact produce or food contact surfaces covered by the PSR (like citrus). This includes water use for irrigation or fertigation, herbicide and pesticide crop sprays, and cleaning and sanitizing harvest clippers, bags, bins and packing lines. Most citrus farms use agricultural water in their operation.
3. What is your water source? If you use water from a municipality (e.g., county or city water) or well water for postharvest activities, you are exempt from an AgWa. You will still need the paperwork showing the water meets the criteria in the rule. If you use surface water (e.g., ponds, canals or seepage irrigation) and that water (whether it is for irrigation or sprays) is likely to contact your citrus, you will need an AgWa.
4. Is your water source protected? Do you monitor your water source and minimize animal intrusion? Or do you allow animals, like cows, into the same water you use for your crops? Are you aware of adjacent animal farms or other activities that may be out of your control, like boaters, which have access to that water? Some intrusion events, including the animals and people recreating, could increase the water’s risk, which must be considered in an AgWa.
5. What are your crops? Document which crop(s) you grow and any crop characteristics, such as information about the crop’s texture. One example is the surface differences between cantaloupe and watermelon. At this point, the rule has no specific examples for citrus. It also includes horticultural practices, such as how you skirt your trees, which could limit the likelihood of water contact from a microjet sprinkler.
6. Does the water directly touch your crop? If yes, your risk may be higher, especially if using surface water. One way to reduce this risk is to extend the time between when water last touched your crop and harvest. FDA guidance suggests a minimum of four days between water use and harvest. Another option is to treat your agricultural water to control human pathogens.
7. Any other factors? Did a wind or freeze event damage your crop? Did you use frost protection? Weather events can impact your crop.

Once you’ve answered these questions, document any changes you may or may not need to make to your operation. For instance, these changes could be extending the time between water application to harvest to a minimum of four days, deciding to treat your water or fencing out animals from your water source. At least once a year, or any time you make changes to your production water practices, update your AgWa. Take a deep dive into the FDA requirements here.

The UF/IFAS Produce Safety Team is here to help you develop your AgWa and address other food-safety needs. From training to technical support visits, the team can help citrus operations achieve regulatory compliance. Visit https://producesafety.ifas.ufl.edu to find out more about our program or email crec-foodsafety@ifas.ufl.edu for scheduling and additional information.

Michelle Danyluk is a professor, Emmy Collins is an education and training specialist, and Taylor O’Bannon is a state food safety Extension agent — all at the UF/IFAS Citrus Research and Education Center in Lake Alfred. William “Billy” Mitchell is a UF education and training specialist, and Keith R. Schneider is a professor, both in the UF Food Science and Human Nutrition Department in Gainesville. Stephanie Brown is a state specialized Extension agent in food science at the UF/IFAS Southwest Research and Education Center in Immokalee.