Pre-Harvest Agricultural Water (Subpart E) Update
Craig Kahlke, Team Leader, Fruit Quality Management
Lake Ontario Fruit Program
FSMA has published a final rule on Pre-Harvest Agricultural Water. Largest growers need to be in compliance by early April 2025. On your FSMA inspection during this year's harvest, inspectors will be checking records and educating in this first year.
This rule applies to water used up to harvest. Pre-harvest ag water includes water you use in your crop protectants and spraying the edible portion of the crop anytime during the growing season.
NOTE: This does not apply to water used at harvest and post-harvest. That final rule is unchanged and folks need to comply now.
You need to do an agricultural water assessment. This is a comprehensive look at your use of ag water on your farm and where the potential risks may be. If the risks are high, you need to have mitigation measures in place to reduce the risks.
==> This rule does NOT require water testing as part of your agricultural water assessment. However, if you currently do water testing for a buyer driven third party food safety audit, you can use these test results in analyzing your water quality and it can be part of your assessment.
==> An agricultural water system assessment--which has been required in the past and is required for a lot of third party buyer-driven audits--is only part of your agricultural water assessment. See the FSMA Produce Safety Rule: Agricultural Water Systems Inspection is Different from the Agricultural Water Assessment document from the Produce Safety Alliance, February 2025, for more information.
FDA Agricultural Water Assessment Factsheet
FDA Agricultural Water Assessment Builder
MS Word Templates (clicking this link will download a set of farm food safety templates created by the Produce Safety Alliance)
If you have not already done so, it is highly recommended that you attend a live webinar or watch a recorded video presentation. Growers who have attended the PSA Grower Training Courses in the past and who have received certificates should have been emailed the information. Sign up to view the video presentation.
Don't hesitate to contact Craig Kahlke (fruit growers) at cjk37@cornell.edu, 585-735-5448, or Robert Hadad (vegetable growers) at rgh26@cornell.edu, 585-739-4065.
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