We ask that the FDA closely consider the science available when determining the water quality standards in the Food Safety Modernization Act for crop spray application water. While we always teach growers the value of water quality, our research showed less effect on the microbial quality on covered produce than we had expected. Enacting the proposed water quality standards on crop spray water without sound scientific evidence may result in unnecessary financial burden on fruit and vegetable growers attempting to comply with FSMA.
The comment illustrates the challenge the FDA has in implementing "science-based" regulations on issues such as water used for the application of crop sprays. This is just one of 1,000 issues that show how time-consuming and difficult writing and implementing the produce safety rule will be.