Day Three of the International Association for Food Protection 2020, A Virtual Annual Meeting featured a round table discussion, “This Is How We Do It: Challenges and Strategies for Implementing Water Treatment in the Field,” with speakers with expert knowledge in agricultural water treatment. This is a vital topic in the world of food safety because water is one of the most likely routes of pathogen contamination during fruit and vegetable production. 

The Food Safety Modernization Act (FSMA) Produce Safety Rule calls for water testing in order to verify the microbial quality of surface water that will contact the edible portion of produce during growing. Growers are being pushed toward the treatment of any surface water that will come into contact with produce before harvest.  

The round table featured the listed professionals:

• Chelsea Davidson, Policy Analyst in the Office of Food Policy and Response contributing to the development of policy, regulations, and guidance related to the Food Safety Modernization Act
• Vicki-Lynne Scott, Agriculture Field Food Safety and Water Industry Consultant
• Channah Rock, Extension Specialist and Professor with the University of Arizona (moderator)
• Michelle Danyluk, Professor & Extension Specialist at the University of Florida (moderator)
• Jay Sughroue, Regional Manager at BioSafe Systems, LLC
• Tim Jackson,  Vice president of food safety, regulatory compliance and social compliance for Driscoll
• Paul Mondragon, Ag Partners Southwest
• Faith Critzer, Associate Professor & Produce Safety Washington State University

Grower guidance is needed on effective treatment and monitoring strategies to ensure an adequate treatment that will reduce environmental impact and will ultimately protect public health. With limited guidance, water treatment decisions are likely to be unsuccessful and expend both excess time and money without the ultimate outcome of reducing generic E. coli and potential pathogen loading within a water source. Under this scenario, the result is little to no reduction in microbiological food safety risk, inconsistent outcomes, and potential damage to irrigated crops and long-term soil health.  Highlighted below are some of the questions these experts were asked and summaries of their answers.

 What are some of the concerns you have about agricultural water treatment? What are the potential problems that keep you up at night? 

This question was fielded by Tim Jackson. Validation is Jackson’s chief concern. He wants to make sure that farm systems are verified and working correctly. “We make sure any water touching fruits and produce is treated,” Jackson said. He also stressed that without treatment, in places like Florida, the water is not fit to be on produce. “We have alligators living in our water.”

From a practical perspective, what challenges do you and your company help overcome? 

This question was directed at Paul Mondragon and Ag Partners Southwest. Mondragon views his company’s role as communicating the water safety metric, defining the terms, and helping farm systems use the metrics to their benefit and the benefit of consumer safety.  Mondragon sees challenges in getting them to implement water safety treatments. “Such as fear, employees that are fearful of chemicals. There is just a general sense of fear with any chemicals.”  He explained that employees also have to clean birds (sprinkler heads) and they are worried about those chemicals and can become aggressive towards technicians as treatment takes place. Mondragon wants his company to lay out the standard operating procedures so that farm systems are comfortable and there is no negligence. In the end, Mondragon says that there are two things to keep in mind and balanced, customers don’t want to pay any extra and they want it to pass all the safety metrics.

How did the Leafy Greens Marketing Agreement (LGMA) arrive at water treatment as the best option for leafy greens? 

Vicki-Lynne Scott said that the FDA’s traceback information found that many leafy green outbreaks have been traced back to water as the likely cause of contamination. “We opted for a risk-based approach,” Scott explained, continuing to say that different water offers more or fewer risks. “Risk varies depending on how it will be supplied. Ground source, furrow, or drip is a lesser risk. Cleaning or sanitizing water needs to be appropriate for that type of use.”

The attributes of a source water

 Jay Sughroue talked about the different attributes of source water that have to be looked at. “When we start looking at different qualities, pH, turbidity, temperature, and organic material,” Sughroue said that agriculture doesn’t often adjust their pH because there is just too much water to adjust. “It’s not something that is done.” He said that if growers and applicators see a large amount of turbidity, they can turn up their treatment. This is for cases like lots of rain. In general, Sughroue said that the higher the temperature the better, but the southwest in the warmer months shows that there are exceptions. “We see an increase in organisms, so they increase the dosage of treatment.” 

How do you help farm systems implement treatment successfully? 

Faith Critzer explained how farm systems have to have intense scrutiny and asked, “Are you doing the right thing? Overall, do you have scientific data to support your threshold limits?” Critzer stressed that each farm system is totally different and needs to be approached differently. It is important, Critzer said, to show farm systems how their treatment operations are going to get to the end goal.  

Efficacy Protocol for Reduction of Foodborne Bacteria in Preharvest Agricultural Water

Chelsea Davidson, who is a policy analyst in the Office of Food Policy and Response and contributes to the development of policy, regulations, and guidance related to the Food Safety Modernization Act, talked about the Efficacy Protocol for Reduction of Foodborne Bacteria in Preharvest Agricultural Water.