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Advancing the science of risk-based criteria for agricultural water quality: Advancing the science of risk-based criteria for agricultural water quality:

Advancing the science of risk-based criteria for agricultural water quality: - PowerPoint Presentation

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Uploaded On 2020-08-05

Advancing the science of risk-based criteria for agricultural water quality: - PPT Presentation

Industry perspectives on the use of riskbased approaches Jennifer McEntire PhD VP Food Safety United Fresh Produce Association FVIAC Aug 14 2019 Key Points Everyone knows ag water quality is important to food safety ID: 799628

risk water produce fda water risk fda produce quality based industry science coli standards assessment 2019 100 generic

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Slide1

Advancing the science of risk-based criteria for agricultural water quality: Industry perspectives on the use of risk-based approaches

Jennifer McEntire, PhDVP, Food SafetyUnited Fresh Produce Association

FVIAC

Aug 14, 2019

Slide2

Key PointsEveryone knows ag water quality is important to food safetyRegulatory requirements are on pause

Industry mindset around managing risk has shiftedLeafy greens producersBreadth of produce industryNext stepsContinue to support scienceSupport science & risk based regulation

Slide3

Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, current Subpart E

“all agricultural water must be safe and of adequate sanitary quality for its intended use” (§ 112.41)water that is intended to, or is likely to, contact the harvestable portion

of

covered produce

or food-contact surfaces (§ 112.3(c))

Requirements on inspection/maintenance of ag water sources and systems, microbial quality, and record-keeping

Microbial limits are specified

Specifies generic

E. coli

as the indicator organism

Slide4

PSR RequirementsMicrobial water quality profile (MWQP)rolling 4-year data set of water testing results

 geometric mean (GM) of 126 or less CFU generic E. coli/100 mL water statistical threshold value (STV) of 410 or less CFU generic E. coli/100 mL water

“Die off

” provision

The requirement for agricultural water used during and after harvest is no detectable generic 

E. coli

 in 100 mL of water. 

Slide5

ChallengesThe mathThe logistics

The methodIs it the right standard?Recreational waterOther hazards

Slide6

Delay of Ag Water Compliance“The extension is designed to provide additional time to ensure the FDA applies the best thinking to

clarify standards for pre-harvest microbial water quality and to continue working closely with produce farmers on sensible approaches to protect consumers”March 15, 2019 Statement from former-Commissioner Gottlieb

https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm633586.htm

FDA needs time to compile and interpret the science

Opportunity for industry to provide input and support

Rulemaking required if updates made to the standards

Slide7

February 2018 “Water Summit”

Slide8

Industry Response(s)

April 2019 – update to LGMA guidelines

Covers ~90% of leafy greens grown in US

Emphasis on evaluating ag water risk based on:

Source, storage, and conveyance

Water use/application

Timing of application

Slide9

Categorizes water into types: A, B, and BA (treated)Defines acceptable uses of water categories

**Open source water must be treated (verified method) if applying overhead within 21 days of harvestCA-LGMA currently working on guidance to help growers validate ag water treatment systems

Slide10

Harmonized Ag Water Working Group

Initiated in 2018 to mitigate varying interpretations on how to conduct a risk assessment

Basic risk assessment ‘decision tree’ based on:

Crop use

Water source

Water delivery system

Application method

Detailed hazard mitigation table

Slide11

Center for Produce Safety

Slide12

Industry Needs

More science; communicate what we already knowCPS, PSA, etc.Continued collaboration with FDA United Fresh shared risk assessment guidanceDeveloping position statement as FDA reevaluates Subpart EBe proactive – don’t wait for FDA