Do You Have Ag Water? Agricultural Water and the Agricultural Water System Inspection

Agricultural water is an essential part of farm operations. It is used in many on-farm activities and plays a significant role in both farmworker health and produce safety. Water can also be a pathway for contamination of fresh produce. Because water is an effective carrier of pathogens, once it becomes contaminated it has the potential to spread that contamination throughout the farm during normal activities.

With pre-harvest agricultural water requirements affecting both large and small farms this spring, now is a good time to discuss agricultural water, the Agricultural Water System Inspection, and the Agricultural Water Assessment.

Do You Have Agricultural Water?

If you grow produce subject to the rule, the answer is almost always yes, you have agricultural (Ag) water. Understanding what qualifies as Ag water and what the FSMA Produce Safety Rule requires is the first step toward compliance and protecting produce safety on your farm.

Under the FSMA Produce Safety Rule, agricultural water is any water that is intended to, or is likely to, contact covered produce or food-contact surfaces. This includes water used for irrigation, frost protection, and handwashing. If you use water during growing, harvesting, packing, or holding activities on your farm, that water likely qualifies as Ag water, and specific regulatory requirements may apply.

What Is an Agricultural Water System Inspection?

If you have Ag Water then an Agricultural Water System Inspection is required. An Ag Water Inspection is an annual review of your entire agricultural water system. Its purpose is to identify conditions that could increase the likelihood of pathogens entering your water system.

The goal of the inspection is for you, the grower, to identify conditions on your farm that could allow pathogens to enter your Ag water system. The inspection is preventative in nature. It is not water testing, nor is it an evaluation of overall risk to your water system, that step comes later in the Agricultural Water Assessment.

Who Must Conduct an Ag Water System Inspection?

If you use agricultural water for covered produce, there is no exemption from the water system inspection requirement. You cannot test your way out of an Ag Water System Inspection. As a grower, using Ag Water, you must conduct:

• At least one Agricultural Water System Inspection per year, and

• Additional inspections following major changes to your system or significant events, such as repairs, flooding, or a change in water source.

  
  

How Do I Conduct an Ag Water System Inspection?

Though we don’t know what the FDA considers an adequate water system inspection, we do know the components a water system must have. From there we can work out what may need to be evaluated including your water sources, distribution systems, connections, backflow devices (or lack of backflow protection), and any points where contamination could occur.

Think of the inspection as reviewing:

• What: Your water source(s); think water type, degree of protection, and your control of the source and system as a whole.

• Where: All points of connection to your water supply, including areas where used water could reenter the system (critical locations for backflow prevention), and adjacent and nearby land use as appropriate.

When conducting your inspection, you are looking for conditions where risk could be introduced, not just visible contamination. Examples could be:

• Cracked or missing well caps

• Dead rodents in irrigation pipes

• Leaks in the distribution system

• Standing water near wellheads

• Dead wildlife in irrigation ponds or streams

If you identify a concern, record it. The purpose of the inspection is to document existing conditions and not to determine risk or  create a corrective action. Finding an issue does not mean automatic noncompliance. It means you have identified a condition that must be evaluated later.

Water system inspection findings are required records and are used to inform the Agricultural Water Assessment.

Recordkeeping and What Comes Next

You must keep records of your Agricultural Water System Inspection. These records must be accurate and dated. Completing the inspection is mandatory and prepares you for the next step: the Agricultural Water Assessment.

The assessment goes beyond identifying conditions. It evaluates the level of hazards and determines whether the water is safe for its intended use.

In next month’s article, we will discuss the Agricultural Water Assessment in more detail. Until then, remember: if you use water for farm activities, you have agricultural water and are required to conduct an Ag water inspection.

For additional clarification on agricultural water or the Agricultural Water Inspection, contact us at miofps.org.

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Article by Micah Hutchison, Produce Safety Technician