Water Quality and the FSMA PSR: Developing Risk Assessment and Educational Tools for Farmers and Laboratories in the Upper Midwest

by Annalisa Hultberg, University of Minnesota Extension

water testing machine with samples sitting on topThe University of Minnesota and Michigan State University, in partnership with the Produce Safety Alliance, are leading a 3-year USDA NIFA FSOP project to help water analysis laboratories and producers better understand the not-yet-finalized agricultural water requirements under FSMA PSR subpart E, and to reduce on-farm risk associated with agricultural water use in the Upper Midwest.

The project is being led in conjunction with an advisory board of farmers, Extension educators and subject matter experts from water analysis laboratories and lab organizations.  The three main audiences for the materials developed are water labs, farmers and Extension educators.  It is important to note that while the FSMA PSR Subpart E water quality standards and testing requirements are currently under re-evaluation, the basic guidance and risk prioritization developed via this project are not expected to change nor be affected by regulatory changes to the PSR. If needed, regulatory aspects of any materials will be updated as needed based on current understanding of regulatory requirements

The first tool will be a guidance tool for water labs relating to quantitative water testing requirements in the FSMA PSR.  This tool will be based on a touch-point analysis in Minnesota and Michigan that is documenting the needs of water labs around providing testing in accordance with the PSR. The needs assessment indicates that labs that have had previous education from Extension about water testing requirements in the PSR are much more aware of the allowable methods and other specifics within the subpart E requirements as currently written.  Labs that have had little education lack an understanding of the rule, and sometimes may mislead growers by indicating, for example, that a drinking water test (which would be a present/absence test) is always adequate for agricultural water. The labs indicate that short videos, SOPs for directing calls from farmers who ask for water testing for the FSMA PSR, and short lab-focused fact sheets about allowable methods and testing standards will be helpful in assuring that they can meet the needs of produce farmers seeking testing for the PSR.

The second tool will be a semi-quantitative Risk Prioritization Tool (RPT) developed for farmers to help them make real-time decisions about water use on their farm based on risks that might be present. The RPT will allow growers to identify situations where the water may not be “safe and of adequate sanitary quality”, a basic requirement of the subpart E water standards, and to have a deeper understanding of risks to their water sources than an E. coli test alone can provide.  

To create this tool, the team will first gather 10 agricultural water samples from each state from a variety of farm environments in the spring of 2022 (a mix of surface and well water) and have the samples analyzed for the presence of generic E. coli (an indication of overall level of fecal contamination) and selected pathogens (e.g., E. coli O157:H7, Salmonella, Listeria monocytogenes and potentially a virus or protozoan target as indicators of actual risk). Risk factors from each farm environment will be documented (such as the upkeep of any co-located septic system, age of the well or proximity of livestock).  The outcome will be a score that can be easily used by farms to classify water sources and use combinations into general risk categories of high, medium, and low, allowing them to make real-time decisions to reduce risk as they use water on their farm.

Finally, the team will create a suite of hands-on table-top demonstration tools to be used in conjunction with the FSMA PSR curriculum and GAPs courses to bring these concepts to life for growers.  The table-tops activities will be developed to be led without the need for technology, and to be very short, making them well suited for PSA Grower Trainings, field days and other GAPs trainings.  Topics will include postharvest water sanitizer use, turbidity measuring, backflow preventors and other topics that relate to water.

All materials will be shared widely in the region and nationally via national partnering organizations. Based on needs identified by community partners, the project has a specific outreach emphasis on working with diverse communities including small-acreage and new farmers, Amish/Plain growers, and Hmong, Latino, and other immigrant and minority farming populations.  Results and outputs will be shared as they are developed over the course of the project timeline from 2021 – 2024.

For more information, reach out to any of the key project staff: Annalisa Hultberg, Phil Tocco, or Don Stoeckel.