NEWARK, DE & WASHINGTON, DC - Food safety is one topic that is always on the table in the fresh produce industry, and the International Fresh Produce Association (IFPA) continues working toward progress. IFPA’s food safety and regulatory team proposed new changes to agricultural water requirements in the produce safety rule during two recent U.S. Food and Drug Administration (FDA) virtual public meetings.

“We commend FDA for proposing this systems-based approach that not only allows, but expects, growers to account for changes in our understanding of science, testing, and risk mitigations,” Dr. Emily Griep, Vice President of Regulatory Compliance and Global Food Safety Standards, said. “Given that roughly half the fruits and vegetables consumed in the U.S. are imported, and because produce is grown in every region of the U.S., it’s critical that the rule be able to accommodate the very different water sources, uses, and types of risks specific to a grower and region. We appreciate that FDA has proposed a rule that moves away from a one-size-fits-all approach.”

In a February 14 meeting, Dr. Griep also outlined how water testing will play a major role in these changes.

“Many produce growers already test their water to satisfy third-party audit requirements, and we don’t expect this to stop,” she said. “We suggest that growers be allowed to leverage historical testing data that provide insight to their water system, but we also believe that testing for generic E. coli, which FDA proposes as a default, is limiting in some situations, and that the rule, as currently written, ostensibly restricts growers from using more appropriate methods and analytes due to the lack of clarity in how to establish that an alternate method is ‘scientifically valid.’”

IFPA is also urging the FDA to continue working closely with stakeholders as additional guidance and resources are developed, according to a press release. During another meeting on February 25, Chief Food Safety and Regulatory Officer Dr. Jennifer McEntire and Director of Food Safety and Quality Gretchen Wall discussed the provisions.

“Industry and academia need to continue building the knowledge base for water assessments, implement mitigations, and start the education process,” Dr. McEntire said. She also acknowledged that the current proposal is much more protective of public health, noting how the comprehensive assessment recognizes that “testing is a tool, not an answer.”

IFPA also encouraged FDA to continue working with produce organizations and educational institutions to make effective, accurate, and science-based resources and educational opportunities available.

“Knowledge of how to conduct a risk assessment is needed to determine the real impact (severity) of a hazard; this will be a fundamental shift in thinking for the industry,” Wall stated. “IFPA is prepared to assist the industry by working with our members, commodity-specific associations, Extension partners, and other stakeholders to develop resources necessary to guide hazard identification and risk assessment.”

The proposed provisions allow microbial die-off without corresponding data for appropriate decision-making, the press release continued. The use of a pre-harvest application interval as a mitigation or corrective measure may be appropriate in certain circumstances, but only with support from a robust risk assessment and relevant supporting scientific data.

“We commend FDA for working collaboratively with EPA towards developing a protocol for reviewing antimicrobial pesticide products for treatment of agricultural water,” Wall continued. “Currently, growers do not have adequate access to registered products to meet the microbial criterion proposed, nor has the industry fully addressed the logistical challenges of consistent application of water treatments. IFPA supports a multi-hurdle approach to mitigations and cautions FDA against asserting that water treatment, or any mitigation currently available, is a silver bullet, especially without access to approved products and supporting science.”

In addition to these meetings, the IFPA will submit comments based on input from a diverse member workgroup to the FDA docket requesting feedback on the proposed changes.

We look forward to the progress that will be made as the IFPA and FDA continue to collaborate.

International Fresh Produce Association