Produce Safety Alliance Offers Free On-Demand FSMA Pre-Harvest Agricultural Water Webinar

PSA Free Pre-Harvest Ag Water Webinar

The Produce Safety Alliance (PSA) is offering a pre-harvest agricultural water webinar in English and Spanish at no cost for past PSA Grower Training Course participants to understand the new requirements. A certificate of completion on the revised Module 5-1 Pre-Harvest Agricultural Water Update will be emailed to webinar participants who attend one full session. Participants can download handouts (English) | (Spanish) to take notes. If you have any questions on the webinar, please contact the PSA team at psatrainers@cornell.edu.

Pre-recorded PSA webinars:

If you have not yet completed the PSA Grower Training course, reduced-cost courses are offered by the University of California Agricultural and Natural Resources (UCANR) as sponsored by the California Department of Food and Agriculture (CDFA). To learn more and register for an upcoming course, please visit the UC Small Farm Food Safety website. Additional upcoming courses can be found on the Produce Safety Alliance website.

Pre-Harvest Agricultural Water, Final Rule Compliance Dates

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

The compliance dates 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) began for Large Farms[1] in April 2025 and for Small Farms[2] in April 2026. The compliance date for Very Small Farms[3] will go into effect in April 2027.

Educational Resources

Resources including educational materials, PSA Grower Trainings, On-Farm Readiness Reviews and the CDFA Technical Assistance Program are available to assist you with preparing for the pre-harvest agricultural water requirements. For more information on these resources, please visit our blog post.

What is Pre-Harvest Agricultural Water?

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

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

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 shifts from an emphasis on testing pre-harvest water to performing agricultural water assessments on pre-harvest water sources. 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 CDFA’s Produce Safety Program, sign up for the Produce Safety Program Mailing List by checking the Inspection Services Division (ISD) / Inspection and Compliance Branch / Produce Safety Program box. To learn more about CDFA’s Produce Safety Program, please visit https://www.cdfa.ca.gov/producesafety/.

[1] Under the FSMA Produce Safety Rule, farms sizes are classified by the average annual gross produce sales adjusted for inflation over a three-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).

[2] “Small” farms have average annual produce sales between $250,000 and $500,000 (adjusted for inflation).

[3] “Very Small” farms have average annual produce sales between $25,000 (adjusted for inflation) and $250,000.

FDA Releases New Frequently Asked Questions (FAQs) Related to Agricultural Water

CDFA PSP Logo FDA Releases Agricultural Water FAQs in front of field being irrigated

On September 30, 2025, the U.S. Food and Drug Administration (FDA) released a constituent update announcing new frequently asked questions (FAQs) related to the agricultural water requirements in the Food Safety Modernization Act (FSMA) Produce Safety Rule, as well as updated information on how it will implement the pre-harvest agricultural water requirements.

The FAQs were developed to provide information about the agricultural water requirements based on topics covered in the final rules, including the following:

  • Inspection and maintenance of agricultural water systems,
  • Pre-harvest agricultural water assessments (including testing as part of an assessment and assessment outcomes),
  • Harvest and post-harvest agricultural water requirements,
  • Corrective and mitigation measures, and
  • Agricultural water treatment.  

The FDA also released updated information about how it plans to implement the pre-harvest agricultural water provisions of the Produce Safety Rule. The updated information focuses on the key elements of the agency’s approach to FSMA implementation, including education (for both industry and regulators), industry training, technical assistance, inspections, and compliance with a commitment to taking an “educate before and while we regulate” approach.

Pre-Harvest Agricultural Water Final Rule Compliance Dates

The compliance date for the pre-harvest agricultural water requirements of the FSMA Produce Safety Rule began 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.

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

[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.

[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.

Additional Resources

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.

FDA Links

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