Although the announcement, “FDA Proposes Changes to Food Safety Modernization Act Rule to Enhance Safety of Agricultural Water Used on Produce,” is a bit to fully digest in one sitting, I’m intrigued by the FDA’s focus on pre-harvest risk assessment of water risk as opposed to water testing for pathogens generally.

The FDA’s requirement of an annual water-risk assessment by farms to “determine whether corrective or mitigation measures are reasonably necessary to reduce the potential for contamination” arguably creates a hazard analysis and critical control point (HACCP) for produce. This requires that produce growers take stock of what pathogen risks surround them on nearby lands, like cattle operations or wild animal populations, that might impact water quality, and take measures to protect produce consumers from possible infection from a deadly pathogen.

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