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Do you know your crop’s characteristics?

Knowing crop characteristics will be necessary for completing the Agricultural Water Assessment, a new part of the FSMA Final Rule on Pre-Harvest Agricultural Water.


This Photo by Unknown Author is licensed under CC BY
This Photo by Unknown Author is licensed under CC BY

The pre-harvest agriculture water assessment is meant to help growers take a more systems-based approach when it comes to hazard identification and risk management on the farm. The written assessment shifts the focus from just testing water to focusing on the entire agricultural water system, including sources of water used and any practices that can help determine what contamination risks may be reasonably foreseeable. Additional assessment considerations include, among other things, crop characteristics and environmental conditions that can impact the survival of pathogens.

 

If a farm is covered under the FSMA Produce Safety Rule, one factor that needs to be considered as part of the new agriculture water assessment is crop characteristics of each commodity grown on the farm. Also consider that the assessment only needs to be completed if a farm has preharvest water that is intended to touch or is likely to touch the harvestable portion on the crop. A farm may not be required to complete an agricultural water assessment if they do not use untreated surface water and the water quality meets the standard of 0 generic E.coli / 100mL when the water is sampled. In the factsheet put out earlier this year from the FDA, crop characteristics are included in the assessment because they affect the susceptibility of environmental hazards and pathogens to stick to the surface of crops or seep into crops.

 

Knowing and listing your crop characteristics can be easier said than done, but it is easiest to start by going back to the basics. Easy characteristics that could be included are noting the crop’s proximity to the ground, the surface texture of the crop, if the crop is prone to surface punctures or bruising which can make it easier for pathogens to enter the crop and noting if the crop is exposed to pooling water or wet soil while it is grown. Other factors that may be harder to determine are knowing if the crop is susceptible to damage from things like freezing or hail, or biological damage from plant diseases that can affect crop quality, and yield.

 

When reading through the FDA responses to comments to the proposed rule, FDA also emphasizes that the absence of a history of outbreaks associated with a specific crop should not be relied upon to determine that the crop has characteristics that naturally make it “safe”. They also note that farms growing many crops can group crops with similar characteristics into categories to make the assessment less lengthy to complete.

 

While we navigate this new requirement, we understand that farms may not yet be equipped with all the needed information to complete this assessment. Although we will not know what enforcement looks like until the rule comes into effect, we recommend reaching out to Conservation District Produce Safety Technicians, MSU Extension, and commodity groups who have access to more resources and research to get you started on the assessment.  


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Article by Allissa Conley, Produce Safety Technician

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