pre-harvest agricultural water – Produce Safety Rules!

The compliance date for the pre-harvest agricultural water requirements of the U.S. Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR) has begun for Large Farms^[1] starting on April 7, 2025. Compliance dates for Small Farms^[2] and Very Small Farms^[3] will follow in 2026 and 2027, respectively.

Pre-Harvest Agricultural Final Rule Compliance Dates

Large Farms: April 7, 2025
Small Farms: April 6, 2026
Very Small Farms: April 5, 2027

Resources including educational materials, Produce Safety Alliance (PSA) Grower Trainings, On-Farm Readiness Reviews and the California Department of Agriculture (CDFA) Technical Assistance Program are available to assist you with preparing for the pre-harvest agricultural water requirements.

Educational Resource Materials

TEMPLATE: PSA Recordkeeping Templates (PDF Version) | (Editable Word Version)
TEMPLATE: FDA Agricultural Water Assessment Builder, Web-Based
TEMPLATE: FDA Agricultural Water Assessment Builder, Paper-Based
WEBSITE: FDA Final Rule on Pre-Harvest Agricultural Water
WEBINAR: FDA Webinar on the FSMA Final Rule on Pre-Harvest Agricultural Water
FDA FACT SHEET: Agricultural Water Assessment (English)
FDA FACT SHEET: Expanded Table on Factors for Agricultural Water Assessment to Consider
FDA FACT SHEET: Annual Agricultural Water Assessments and Risk-Based Outcomes
FDA FACT SHEET: Corrective and Mitigation Measures for Pre-harvest Agricultural Water for Non-Sprout Covered Produce
Electronic Code of Federal Regulations: Subpart E Agricultural Water

Produce Safety Alliance Grower Trainings

The current PSA Grower Training Course curriculum includes the new pre-harvest agricultural water rule requirements.

The CDFA Produce Safety Program (PSP) offers PSA Grower Training courses at no cost for all California residents. If you have not yet completed a PSA Grower Training course or would like to receive a refresher, please visit https://www.cdfa.ca.gov/producesafety/growertraining/ for course dates.

PSA is also hosting update webinars at no cost for past course participants to understand the new pre-harvest agricultural water requirements. A certificate of completion will be emailed to webinar participants who attend one full session (only one session needs to be attended). Registration is required and participants must join the webinar within 15 minutes of the start time to receive a certificate. Participants can download handouts (English) | (Spanish) to take notes. If you have any questions on these webinars, please contact the PSA team at psatrainers@cornell.edu.

Upcoming live webinars in English:

May 8, 2025, 9AM – 11AM PT. Register Here.
July 10, 2025, 11AM – 1PM PT. Register Here.

Upcoming live webinars in Spanish:

June 5, 2025, 9AM – 11AM PT. Register Here.
Aug 13, 2025, 8AM – 10AM PT. Register Here.

Pre-recorded PSA webinars:

On-Farm Readiness Reviews

Produce growers and handlers that have not yet undergone their initial PSR inspections are encouraged to request an On-Farm Readiness Review (OFRR) to aid in their preparation process.

An OFRR is a free, voluntary, customized assessment conducted before an initial regulatory inspection that includes a farm walk-around and one-on-one conversations with CDFA PSP staff to discuss how the PSR applies to your operation in a confidential, educational format.

OFRRs can be requested by emailing producesafety@cdfa.ca.gov. Additional information on OFRRs can be found on our OFRR Blog Post.

CDFA Technical Assistance Program

Produce growers and handlers can receive one-on-one technical assistance at no cost by requesting to be connected to the CDFA Technical Assistance Program (TAP). CDFA TAP is a service that offers educational resources and food safety support for produce operators in California.

CDFA TAP participants will be connected to a Technical Assistance Provider from the University of California Cooperative Extension team who can provide customized support on pre-harvest agricultural water rule compliance and inspection preparation.

Request CDFA TAP support by emailing producesafety@cdfa.ca.gov and learn more at https://www.cdfa.ca.gov/is/technicalassistance/.

What is Pre-Harvest Agricultural Water?

Pre-Harvest Agricultural Water refers to water used during growing activities where water is intended to, or is likely to, contact covered produce or food contact surfaces.

Examples of growing activities can include irrigation, crop sprays, fertigation, cooling, frost protection, dust abatement and any other uses where water directly contacts produce or food contact surfaces.

Covered produce means produce that is subject to the requirements of the Produce Safety Rule including the harvestable or harvested part of the crop.

Background on the Pre-Harvest Agricultural Water Final Rule

On May 6, 2024, FDA published a final rule on pre-harvest agricultural water revising certain requirements in Subpart E of the FSMA Produce Safety Rule (PSR) for covered produce (other than sprouts) for enhanced produce safety. The new rule moves from an emphasis on testing pre-harvest water to performing an agricultural water assessment. It does not change existing agricultural water requirements for sprouts or harvest and post-harvest water uses. The final rule went into effect on July 5, 2024.

If you have questions about the Produce Safety Rule, please contact producesafety@cdfa.ca.gov.
To stay up to date with news related to the California Department of Food and Agriculture (CDFA) Produce Safety Program, sign up for the Produce Safety Program Mailing List by checking the Inspection Services Division (ISD) / Produce Safety box
To learn more about CDFA’s Produce Safety Program, please visit https://www.cdfa.ca.gov/producesafety/

^[2] “Small” farms have average annual produce sales above $250,000 and up to $500,000 adjusted for inflation.

^[3] “Very Small” farms have average annual produce sales above $25,000 and up to $250,000 adjusted for inflation.

On May 6, 2024, the U.S. Food and Drug Administration (FDA) published a final rule on pre-harvest agricultural water revising certain requirements in Subpart E of the FSMA Produce Safety Rule (PSR) for covered produce (other than sprouts) for enhanced produce safety.

The new rule replaces the prior pre-harvest water microbial quality criteria and testing requirements with requirements for systems-based agricultural water assessments for hazard identification and risk management. Agricultural water assessments will now need to be conducted once annually, and whenever a significant change occurs that increases the likelihood of hazards being introduced to produce or food contact surfaces. The new rule does not change existing agricultural water requirements for sprouts or harvest and post-harvest water uses.

FDA states this new rule:

Establishes requirements for agricultural water assessments that evaluate a variety of factors that are key determinants of contamination risks associated with pre-harvest agricultural water. This includes an evaluation of the water system, water use practices, crop characteristics, environmental conditions, potential impacts on water from adjacent and nearby land, and other relevant factors.
Includes testing pre-harvest agricultural water as part of an assessment in certain circumstances.
Requires farms to implement effective mitigation measures within specific timeframes based on findings from their assessments. Hazards related to certain activities associated with adjacent and nearby land uses are subject to expedited mitigation.
Adds new options for mitigation measures, providing farms with additional flexibility in responding to findings from their pre-harvest agricultural water assessments.

The final rule is effective July 5, 2024. Compliance dates for the pre-harvest agricultural water requirements for covered produce (other than sprouts) are as follows^[1]:

For Large farms: April 7, 2025 (9 months after the effective date of the final rule)
For Small farms: April 6, 2026 (1 year, 9 months after the effective date of the final rule)
For Very Small farms: April 5, 2027 (2 years, 9 months after the effective date of the final rule)

If you have questions about the Produce Safety Rule, please contact producesafety@cdfa.ca.gov.

To stay up to date with news related to the California Department of Food and Agriculture (CDFA) Produce Safety Program, sign up for the Produce Safety Program Mailing List by checking the Inspection Services Division (ISD) / Produce Safety box
To learn more about CDFA’s Produce Safety Program, please visit https://www.cdfa.ca.gov/producesafety/

Additional Resources:

^[1]Under the FSMA Produce Safety Rule, farms sizes are classified by the average annual gross produce sales adjusted for inflation over a 3-year period. Click here to learn more about the FSMA Inflation Adjusted Cut Offs. “Large” farms have average annual produce sales above $500,000 adjusted for inflation. “Small” farms have average annual produce sales above $250,000 and up to $500,000 adjusted for inflation. “Very Small” farms have average annual produce sales above $25,000 and up to $250,000 adjusted for inflation.

Tag: pre-harvest agricultural water

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