Trevor Suslow has addressed confusion over water compliance dates for the produce safety rule. ( File photo )

A misunderstanding of proposed agricultural water compliance dates for the produce safety rule has been addressed by produce safety trainer Trevor Suslow.

Writing on the University of California’s Postharvest Center website, Suslow, director of the Postharvest Technology Center, explained the confusion over the dates.

“The purpose of this communication is to assist in correcting this situation and supporting Produce Safety Alliance efforts to have one standardized message on agricultural water testing as the specific provisions and requirements evolve and are resolved,” Suslow wrote.

From communications with FDA officials, Suslow lists on the website the dates when water testing must be initiated. According to the latest information and rulemaking, the start of microbial indicator testing for agricultural water won’t be a compliance requirement for larger businesses (over $500,000 in sales) until Jan. 26, 2022.

A full list of compliance dates is available at the Postharvest Center website.


Submitted by Victor Tognazzini on Tue, 02/27/2018 - 10:14

I am certainly not attacking the messenger, Trevor Suslow, but it is ludicrous to allow four years for larger businesses to start microbial indicator testing for agricultural water. LGMA members were being audited on metrics that included the results of water testing 3 to 4 months after sign-up. Setting up water testing involves contacting a lab, identifying water sources and initiating testing. Why would a business wait four years to have critical information to food safety? Why would any business, regardless of size be exempt from testing requirements? Pathogens do not discriminate by the size of a business!

Submitted by Trevor Suslow on Tue, 02/27/2018 - 21:37

Typically, I don't read or engage in comment exchanges where I may be incidentally mentioned or included in an article. However, I initiated this and Tom Karst was generous enough to include the note for his readership so I do feel an obligation to participate. I am passionately in agreement with you, Victor, and it is hard to sell the urgency of concern around the specific risk profile of preharvest water across all scales of production during grower training's if the dates for compliance are pushed out for several years. Regardless, many of us are currently attending the FSMA Water Quality Summit in KY and, as FDA has been acutely aware, few regions have access to labs prepared to offer these services in a location which would allow sample submission in the current required time frame, let alone have a clear and practical resolution to a myriad of compliance definitions and implementation uncertainties. For larger growers with over a decade long experience and deep archive of comparable water testing this is a relatively trivial adjustment. For many others, the proposed extended compliance dates which allow for more data gathering and reassessment by FDA is a sensible measure to promote broader compliance and more meaningful food safety objectives in the future.

In reply to by Victor Tognazzini (not verified)

Submitted by Victor Tognazzini on Thu, 03/01/2018 - 12:58

Thank you Trevor for your comments and insights into the issue of water testing. I appreciate that knowledge and appreciate your dedication to the advancement of food safety protocols.

In reply to by Trevor Suslow (not verified)

Restricted HTML

  • Allowed HTML tags: <a href hreflang> <em> <strong> <cite> <blockquote cite> <code> <ul type> <ol start type> <li> <dl> <dt> <dd> <h2 id> <h3 id> <h4 id> <h5 id> <h6 id>
  • Lines and paragraphs break automatically.
  • Web page addresses and email addresses turn into links automatically.
16 + 2 =
Solve this simple math problem and enter the result. E.g. for 1+3, enter 4.