Food Safety Virtual Office Hours: Navigating the FSMA PSR Preharvest Agricultural Water Assessment

Why It Matters

The revised rule forces growers to adopt a risk‑based, documented water‑management approach, directly affecting compliance costs, inspection outcomes, and ultimately consumer safety.

Key Takeaways

• FDA revised FSMA PSR Subpart E, shifting to water assessments.
• Assessments must be documented, signed, and justified for inspectors.
• Implementation deadlines vary: large, small, and very small businesses.
• Agricultural water includes pre‑harvest, post‑harvest, and food‑contact uses.
• Use FDA’s assessment builder, but identify critical hazards yourself.

Summary

The virtual office hours focused on the FDA’s May 2024 revision to Subpart E of the FSMA Produce Safety Rule, which replaces the historic reliance on microbial testing with a comprehensive agricultural water assessment. Panelists from the Produce Safety Alliance, Cornell University, state agencies, and growers explained that growers must now evaluate their entire water system, justify decisions, and be prepared to demonstrate that rationale to inspectors.

Key points included the shift from a water‑quality profile to a risk‑based assessment covering source, distribution, use practices, crop characteristics, and environmental conditions. Implementation dates are staggered—large operations by April 7 2023, small businesses by April 6 2024, and very small farms by April 5 2025—so compliance timelines differ across the industry. The rule defines agricultural water broadly, encompassing pre‑harvest irrigation, post‑harvest wash water, and water contacting food‑contact surfaces, while excluding uncontrolled sources like rain.

During the discussion, panelists highlighted practical nuances: potatoes are not “covered” produce and thus their irrigation water is not agricultural water; rain, though it contacts crops, is excluded because growers cannot control it. They also praised the FDA’s assessment‑builder tool for guiding documentation, noting its limitation in pinpointing the most critical hazards. Real‑world examples illustrated how delivery methods (drip vs. overhead) and climate variability affect risk assessments.

The implications are clear: growers must develop written, signed assessments annually and whenever significant changes occur, integrating hazard identification, risk evaluation, and mitigation strategies. Failure to do so can trigger compliance actions during inspections, potentially disrupting market access and increasing operational costs. Early adoption of the assessment framework positions producers to meet regulatory expectations and protect public health.

Original Description

This session of Food Safety Virtual Office Hours features Dr. Elizabeth Bihn, Director of the Produce Safety Alliance, Dept. of Food Science, Cornell University, presenting an update on FSMA Produce Safety Rule Revised Subpart E: Agricultural Water and discussion about agricultural water assessment of the whole water system.

Important note: The information provided here is current up to the date of its recording on Wednesday, March 25, 2026. For more information, visit the IFS@CU's website: https://cals.cornell.edu/institute-for-food-safety