The new auditable agriculture water standards adopted a week ago by California’s leafy greens industry were embraced Thursday by two powerful industry groups.

Testing water for pathogens has always been required by the California Leafy Greens Marketing Agreement (LGMA). But in response to three consecutive E. coli outbreak associated with romaine lettuce, the LGMA last week adopted “additional safeguards” that require growers to categorize their water sources, consider when and how it is applied to crops, conduct testing to be sure the water is safe for its intended use, and sanitize the water if necessary and verify all precautions are taken.

Signing on to the additional standards are the United Fresh Produce Association and the Produce Marketing Association (PMA).

“This is a paradigm shift in ag water management,” said Dr. Bob Whitaker, PMA Chief Science Officer. “The key now is to undertake the education and training needed to implement the new metrics and most importantly, to begin learning about the effectiveness of the water metrics and continually improving them as the industry gathers data and distills the performance information.”

The industry’s Romaine Task Force is co-chaired by United Fresh and PMA. It participated in the development of the new agriculture water standards. It will now evaluate the risk-based approach from the perspective of the leafy green supply chain.
The newly adopted LGMA ag water standards require growers to characterize, treat, and monitor all forms of surface water used for overhead irrigation of leafy greens within 21 days of harvest.

The FDA included this Google Earth view in its memorandum on the environmental assessment related to the E. coli outbreak. It shows a section of the Wellton canal that is adjacent to a 100,000-head feedlot. Portions of this image (in gray) were redacted by the government. However, the FDA report says the image shows the locations of the feedlot, sites where E. coli-positive water samples were collected, unlined sections of the irrigation canal, and a retention pond at the feedlot. The water in the canal flows from west to east. Click to enlarge image.

“This effort represents a fundamental shift to better reflect well-established scientific knowledge on how we should think about water quality and risk,” said Jennifer McEntire, United Fresh’s vice president of food safety and technology. “We are no longer working on the assumption that water is based on a periodic, by the calendar, water test result; instead the industry assumes that surface water may present a risk to leafy greens and proactively treating it during the period closest to harvest.”

United Fresh has represented the produce industry for 115 years. PMI works to expand sales and increase consumption of domestic produce. California and Arizona LGMAs promote their specific growing regions.

More than 50 billion servings of lettuce and leafy greens are grown annually in California and Arizona. About 95 percent of all lettuce produced in the U.S. is grown in the two states.

The LGMAs were formed after the 2006 nationwide outbreak of E. coli that was associated with freshly bagged spinach. Large grocery store and restaurant chains along with major distributors came to purchase only from growers who are “LGMA certified.”

LGMA growers and distributors have audited an average of five times a year to verify their compliance with the agreement’s science-based food safety practices and for standards that meet or exceed the federal Food Safety Modernization Act’s Produce Safety Rule.

The more recent E. coli outbreaks, which began in late 2017 and continued into early 2019, brought a top-to-bottom review of Romaine growing practices. Both the U.S. Food and Drug Administration (FDA) and the industry are investigating and focused on water. Irrigation water from both canals and reservoirs have come under scrutiny by both the government and the industry.

The new LGMA agriculture water standards also have the benefit of being imposed immediately on growers. The FDA Food Safety Modernization Act (FSMA) Produce Safety Rule includes agricultural water requests, but the agency opted to postpone the compliance dates.

Except for sprout growers, large produce farms are not required to comply with the agricultural water requirements until Jan. 26, 2022. Small farms have until Jan. 26, 2023; and very small farms have until Jan. 26, 2024.

Open air canals run through the desert, past feedlots, and into the irrigation water systems of produce growing operations. Here the feed containers of a huge feedlot can been seen in the background. Photo by Cookson Beecher

When it gave American agriculture more time to comply with the water requirements, FDA said it did so because of the complexity involved.

“Recent outbreaks potentially linked to agricultural water have highlighted just how diverse agricultural production is, and have stressed the importance of ensuring that these standards are workable across the diversity of farms, water sources, and uses,” the agency’s extension announcement said. “FDA remains firmly committed to incorporating lessons learned from these recent outbreaks, and to using the best science available to help minimize the risk that produce can become contaminated.”

Since early 2019, the LGMAs have made multiple changes to their standards. In addition to the new agricultural water standards, California has imposed large buffers for areas between growing areas and feedlots with more than 1,000 animals. Arizona’s LGMA has strengthed equipment cleaning requirements, required specific action involving wind or flooding events, imposed mandatory traceability measures, and added buffers on feedlots.

After the deadly 2017-19 E. coli outbreaks that sickened almost 300 and killed six people, the LGMAs are looking to restore confidence with their quick, private action.

“This means that every box of leafy greens placed into commerce by a certified LGMA member will now be produced under new, more stringent requirements,” said Scott Horshall, CEO of the LGMA for Calfornia. “We have effectively changed the way leafy greens are farmed.”

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