Food-safety rule focuses on water quality

Issue Date: August 21, 2013
By Kate Campbell
Armando Chavez, food safety director for Rio Farms near King City, samples water from sprinklers irrigating a celery field. During the warm growing season, Chavez says, water samples are tested weekly.
Photo/Richard Green
Rio Farms Manager Bob Martin, right, checks water clarity during routine water sampling with food safety director Armando Chavez.
Photo/Richard Green

Editor's note: This is Part 3 of a series of stories about how proposed federal food-safety rules could affect California farmers and ranchers.

Managing water has always been a priority on farms and ranches across California, but the job could become more complex and costly under newly proposed federal food safety rules.

Proposed rules for irrigation water standards under the Food Safety Modernization Act—released in January by the U.S. Food and Drug Administration—would cover fresh fruit and vegetables. Farmers are reviewing the proposal and preparing to comment before the opportunity for public comment on the entire proposal ends in mid-November.

"California and Arizona vegetable farmers are already doing most of what is proposed under FSMA," said Bob Martin, manager of Rio Farms in the Salinas Valley. "We're following standards required under the Leafy Greens Marketing Agreement, plus doing a lot more on our own ranches."

FDA said its proposed requirements for agricultural water safety draw heavily on the standards set by the LGMA, along with standards for tomato growers in Florida and the U.S. Department of Agriculture Good Agricultural Practices guides.

"What kind of sticks in my craw is that initially FSMA was going to focus more on commodities that have given more 'bellyaches' to the public," said Martin, a former Monterey County Farm Bureau president. "We were looking for commodity-specific guidelines, but I think FDA realized how much work was involved and broadened it to just two categories."

The proposed rules for water safety exempt commodities that need cooking, such as artichokes and potatoes, and focus on commodities that are usually consumed fresh.

"With FSMA, we're going beyond leafy greens to irrigation water safety requirements for many other crops, like bulb onions, which have never been named in a food-borne illness," Martin said. "Lumping commodities together makes it easier for the FDA and much tougher for farmers."

FDA said the proposed produce rule would establish science-based minimum standards for the safe growing, harvesting, packing and holding of produce in its raw or natural, unprocessed state on farms. This would include, for example, lettuce, spinach, cantaloupe, tomatoes, sprouts, mushrooms, onions, peppers, cabbage, citrus, strawberries and walnuts.

The rules on agricultural water safety include groundwater and a variety of surface water sources—ponds, rivers, creeks and canals, as well as municipal and water district supplies. FDA said it is aware that farmers don't have control of many upstream land and water uses and recognizes in many parts of the country water is often in short supply.

The proposed rule for untreated surface irrigation water requires sampling and testing at least every seven days during the growing season. In addition, on-farm reservoirs must be protected from runoff and tested monthly during the growing season.

"This section of the proposed rules has given rise to a lot of discussion," said Judith Redmond, an organic grower and owner of Full Belly Farm in Yolo County. "A number of water districts have been contacted by farmers suggesting centralized testing be allowed, rather than having every farmer along the same canal do their own, independent testing."

The real rub, Redmond said, "is what to do when you come up with a positive test. Some farmers may be able to dilute their water, but many will not."

In addition, she said, "We need to take a careful look at the accuracy of testing and tradeoffs in testing for generic E. coli vs. pathogenic O157:H7, and most importantly look at how we can protect our water sources."

Gurmail Mudahar, vice president of food safety for the vegetable grower-shipper Tanimura and Antle in Salinas, said it has been testing irrigation water every month for years and has developed a strong database.

"We feel testing every month using the LGMA guidelines is working pretty well," Mudahar said. "We don't find California rivers and canals are contaminated. Testing every seven days is overkill. There would just be more expense on the grower side and no added value for the consumer."

Whatever the final FDA food safety rules look like, Coco Farms owner Jennifer House said FSMA adds complications, and she has concerns about balancing all the requirements with USDA Good Agricultural Practices. Her organic apple farm near Dixon was USDA certified last year, which helps her meet requirements from the packinghouse where she sends her apples.

"We haven't talked with the packinghouse yet about what FSMA will mean in terms of their expectations," House said, adding that she sees the proposed rules as a way to shift liability for outbreaks of food-borne illness from government and retailers back to the farm.

"You can calculate what FSMA will cost, but can't calculate what legal costs will be. Farmers will need to follow the rules and maintain a strong position," she said.

Many agricultural groups have issues with FSMA as currently proposed, said Scott Horsfall, CEO of the California Leafy Greens Marketing Agreement, but the water requirement is very similar to the LGMA rules that growers have been following.

"The real problem we have with the proposed water rule is the weekly testing of surface waters," Horsfall said. "Like others, we think that's excessive."

The FSMA Water Fact Sheet may be read online at

(Kate Campbell is an assistant editor of Ag Alert. She may be contacted at

Next week: Proposed federal food-safety rules govern the training, health and hygiene of farm employees, plus management of equipment, tools and buildings.

Permission for use is granted, however, credit must be made to the California Farm Bureau Federation when reprinting this item.

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