The Leafy Greens Marketing Agreements in Arizona and California, which exist to promote food safety for lettuce and leafy greens, report that they have conducted an initial review of FDA’s new rule for agricultural water and they’ve found LGMA’s current requirements “meet and exceed” what is in the proposed new rule.

LGMA growers in California and Arizona produce more than 90 percent of the leafy greens grown in the United States. Those growing areas, mostly from 2016 to 2019, have experienced outbreaks of E. coli O157:H7 from their fields of romaine and leafy greens.

The U.S. Food and Drug Administration (FDA) on Dec. 2 announced the release of a proposed revision to Subpart E (Agricultural Water) of the Produce Safety Rule (PSR).  Frank Yiannas,  FDA Deputy Commissioner for Food Policy and Response, told  Food Safety News  the proposed rule is a “game-changer.”

The proposed change in  the FDA agricultural water rule for produce growers regarding food safety measures will change the face of public health even though it will also eliminate some water testing requirements, according to Yiannas.

“These changes will result in a major shift in what industry has been doing,” he said.  The proposed rule regarding agricultural water safety will use effective, modern, science-based measures designed to prevent foodborne outbreaks. A key difference in the proposed rule is that much of the pre-harvest pathogen testing of irrigation water will no longer be required. Instead, growers would be required to annually assess a variety of possible problems and implement ways to resolve them.”

Leaders with the LGMA programs say they have always required growers to assess and test their water because it can be a potential carrier of pathogens.

In 2019 LGMA requirements were updated to include additional safeguards designed to ensure growers: categorize the source of the water; consider how and when water is applied to the crop; conduct water testing to assure the water is safe for the intended use; treat water if necessary; and verify that all the above precautions have been taken.

The LGMAs call this a systems approach, and they say FDA is proposing similar methodology in their proposed water requirements.

FDA in 2015 published the Produce Safety Rule as a part of the Food Safety Modernization Act of 2011. Both LGMA programs worked with FDA subject matter experts to align their guidelines with the Produce Safety Rule.

Both organizations were formally recognized in 2017 by FDA for aligning their food safety standards (also called guidelines or metrics) with FDA’s Produce Safety Rule. It is a priority for both organizations to align with FDA requirements.

The Arizona and California LGMA’s leaders say they applaud FDA for its work to enhance water requirements under the Produce Safety Rule. FDA has initiated a 120-day comment period on the proposed revision, which will be followed by the FDA rulemaking process. The LGMA organizations will be submitting comments to FDA. When the final rule is approved the LGMA programs will review and if needed quickly make changes to ensure their metrics remain aligned with FDA requirements, according to LGMA leaders.

The LGMAs verifies food safety practices, enforces through government audits, and requires a commitment to continuous improvement.

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